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Samara Carpets Private Limited vs. ACIT, CPC Tax-TDS

Case No: ITA Nos. 5019, 5020 & 5021/Del/2026
Court: Income Tax Appellate Tribunal, Delhi Bench
Date: 9/10/2026

Parties Involved

AppellantSamara Carpets Private Limited
RespondentACIT, CPC Tax-TDS

Facts Summary

The assessee, Samara Carpets Private Limited, filed three appeals (ITA Nos. 5019, 5020 & 5021/Del/2026) for assessment years 2013-14, 2015-16, and 2014-15 against the orders of the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre, Delhi. The appeals were filed under section 200A of the Income-tax Act, 1961. The assessee argued that the late filing fee under section 234E was wrongly levied, the interest under section 220(2) was invalid, and the penalty order under section 154 was void. The Department argued that the late filing fee was correctly levied.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the levy of late filing fee u/s. 234E for F.Y. 2013-14 was erroneous.
  • 2. Whether the NFAC erred in holding that the Section 154 rectification application was not maintainable.
  • 3. Whether the NFAC erred in ignoring the judicial precedents on the levy of fee u/s. 234E.
  • 4. Whether the interest levied u/s. 220(2) was valid.
  • 5. Whether the penalty order u/s. 154 was valid.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

7 precedents cited in this judgement.

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Samara Carpets Private Limited vs. ACIT, CPC Tax-TDS | ITA Nos. 5019, 5020 & 5021/Del/2026 | 2026 | Opakhya