An examination of ITA No. 1363/Del/2021, where ICMC Projects Pvt. Ltd. contests late fee charges levied by ITD, CPC, Bengaluru for the assessment year 2013-14 Q2.
The case centers on the applicability of late fees under Section 234E for the delayed filing of TDS statements. ICMC Projects Pvt. Ltd. faced late fees for filings related to the second quarter of the 2013-14 fiscal year.
The tribunal reviewed whether the application of late fees under Section 234E before the amendments introduced by the Finance Act 2015 was justifiable. This act, effective from June 1, 2015, introduced specific provisions for computing fees for delayed filings.
The tribunal sided with decisions favorable to the taxpayer, given the conflicting higher court rulings on the retrospective application of legislative amendments. It emphasized that the late fee provisions could not be applied retrospectively, leading to the cancellation of the late fees imposed on ICMC Projects Pvt. Ltd.
The case outcome highlights critical insights into the interpretation of tax laws concerning procedural changes and their effective dates. It underscores the judiciary’s role in safeguarding taxpayer rights against retroactive tax claims.
The tribunal’s decision was pronounced openly in court on February 25, 2022, setting a significant precedent for similar cases.
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