Chronicle Publication Pvt Ltd vs ACIT (CPC)-TDS, New Delhi for AY 2014-15 Qtr 24(Q-1) – ITA No. 6312/DEL/2019

Case Overview

This case involves Chronicle Publication Pvt Ltd, New Delhi, as the appellant and ACIT (CPC)-TDS, New Delhi, as the respondent. The dispute is for the assessment year 2014-15, concerning the first quarter under section 24(Q-1). The case was filed on 2019-07-26, with a final tribunal order pronounced on 2020-08-31.

Background

The case pertains to penalties imposed under section 234E for late filing of TDS statements before the amendment to section 200A of the Income Tax Act, which was effective from June 1, 2015. The appellant argued against the levy of penalties for returns filed before this amendment, emphasizing the retrospective application of the law.

Judgment Summary

The tribunal, after reviewing the submissions and relevant legal provisions, concluded that penalties under section 234E could not be retrospectively applied to periods before the amendment of section 200A. Thus, penalties imposed for TDS statements filed before June 1, 2015, were not justified. The decision was based on the principle that laws affecting substantive rights cannot be applied retrospectively unless explicitly stated.

Conclusion

The case highlights the importance of the date of effect of legislative amendments and their impact on ongoing assessments. It serves as a crucial reference for cases involving disputes over the applicability of tax laws and amendments.

आयकर आयकर आयकर आयकर अपीलीय अपीलीय अपीलीय अपीलीय अिधकरण अिधकरण अिधकरण अिधकरण , /g7408द/g7016ली /g7408द/g7016ली /g7408द/g7016ली /g7408द/g7016ली आदेश.

Chronicle Publication Pvt Ltd vs ACIT (CPC)-TDS, New Delhi for AY 2014-15 Qtr 24(Q-1) – ITA No. 6312/DEL/2019