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TDS late filing u/s 234E

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19 November 2025 Dear Sir, the late filing fee U/s.234E are there for the F.Y. 2012-2013-2014-2015. I understand that up to the F.Y. 2015-2016, the above said section does not have the proper legal back up, hence may be challenged. Is it correct sir? if so, some back ground on this is requested.
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Dhirajlal Rambhia

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Dhirajlal Rambhia (Expert)
20 November 2025 Late filing fees under Section 234E for TDS returns became applicable from 1st July 2012.
The fee is considered a mandatory levy and not discretionary.
Courts have upheld its constitutionality, especially post-2015 when CPC-TDS began issuing intimations under Section 200A including 234E fees.
CPC-TDS started levying 234E fees through intimation orders from 1st June 2015 onwards, but the legal provision was in force from 1st July 2012 itself.
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