Analysis of Chronicle Publication Pvt Ltd vs. ACIT (CPC)-TDS, New Delhi for Assessment Year 2013-14 Qtr – 24(Q-4) – ITA 6311/DEL/2019

Case Overview

Case Number: ITA 6311/DEL/2019

Appellant: Chronicle Publication Pvt Ltd, New Delhi

Respondent: ACIT (CPC)-TDS, New Delhi

Assessment Year: 2013-14 Qtr – 24(Q-4)

Case Filed On: 2019-07-26

Order Type: Final Tribunal Order

Date of Order: 2020-08-31

Pronounced On: 2020-08-31

Case Summary

The Income Tax Appellate Tribunal Delhi Bench ‘A’, presided over by Ms. Sushma Chowla, VP, and Dr. B.R.R. Kumar, AM, heard the case through video conferencing.

The key issue involved was related to the assessment of Chronicle Publication Pvt Ltd for the fourth quarter of the assessment year 2013-14. The appellant contested the intimation under section 200A(3) issued by the Assessing Officer, which led to the tribunal hearing.

The judgment emphasized the non-applicability of the late filing fee under section 234E prior to its amendment through the Finance Act, 2015, effective from 01.06.2015. It was determined that the Assessing Officer was not empowered to levy this fee for TDS statements filed for periods before this date.

The tribunal also discussed the legislative intent behind the amendments and highlighted the specific retrospective applications of tax laws, leading to the appellant’s relief.

The decision was crucial for understanding the procedural aspects concerning the processing of TDS statements and the imposition of related fees.

Conclusion

The tribunal concluded that Chronicle Publication Pvt Ltd was not liable for the late filing fees under section 234E for the concerned periods as the relevant laws were not applicable retrospectively. This case sets a significant precedent for similar disputes regarding the timeline of legislative changes in tax laws.

Analysis of Chronicle Publication Pvt Ltd vs. ACIT (CPC)-TDS, New Delhi for Assessment Year 2013-14 Qtr – 24(Q-4) – ITA 6311/DEL/2019