Held that Section 234E of the Income-tax Act, 1961 was introduced by the Finance Act, 2012 ((2012) 345 ITR (St.) 10) with effect from July 1, 2012. It provides for levy of late fee for not filing the statement of tax deducted at source. The amendment was to take effect only from June 1, 2015 and was thus prospective in nature. The jurisdiction to levy late fee under section 234E of the Act, arises only from June 1, 2015 and not earlier. Accordingly, that the imposition of late fees under section 234E of the Act, was not valid. Court also held that, since in matters where total lack of jurisdiction is alleged, delay cannot be relied upon as a ground to deny the relief, the objections of the Income-tax Officer were without any basis.(AY. 2012-13 to 2014-15)