Dismissal of Appeal for Late Filing Fee under Section 234E: A Detailed Case Analysis of ITA No.1339/Del/2022
In the case number ITA No.1339/Del/2022, the Income Tax Appellate Tribunal (Delhi Bench ‘H’) addressed an appeal filed by Yogender Kumar of Ballabhgarh, Faridabad against the Income Tax Officer (ITO), Ward-2(5), Faridabad for the assessment year 2019-20. The core issue revolved around the imposition of a late filing fee under Section 234E of the Income Tax Act, 1961, for the assesse’s failure to promptly file a TDS return.
Background
The appellant, Yogender Kumar, was penalized for not filing the TDS statement on time, which led to a late filing fee of Rs.1,59,200. The deduction at source (TDS) in question was related to a property transaction, mandating a 1% TDS to be deducted and deposited by the buyer under Section 194IA. Though the TDS was eventually deposited, the failure to file the return in due time resulted in the punitive fee.
Judgment
Upon reviewing the case, the Tribunal, comprising SHRI SAKTIJIT DEY, Vice-President, and SHRI GIRISH AGRAWAL, Accountant Member, dismissed the appeal. The judgment highlighted that the assessee’s non-compliance with the filing deadline, despite having deducted and deposited the TDS, warranted the late filing fee as per the provisions of the Income Tax Act.
Legal Analysis
The Tribunal’s decision underscored the importance of adhering to tax filing deadlines, placing significant emphasis on the legislative amendments post-1st June 2015 that have empowered authorities to enforce compliance more strictly. This case illustrates the broader implications of such amendments, serving as a stern reminder to all stakeholders of the critical nature of compliance within the stipulated timelines.
Conclusion
This analysis not only sheds light on the specifics of ITA No.1339/Del/2022 but also contextualizes the legal framework governing TDS filings and associated penalties. For taxpayers, it serves as a crucial learning point about the significance of timely compliance with tax obligations, and for professionals, it provides a detailed judicial perspective on dealing with cases of late filing fees under Section 234E.
