The Tribunal referred to the decision of the Hon’ble Kerala High Court in the case of Olari Little Flower Kuries (P.) Ltd. v. UOI (2022) 440 ITR 26 (Ker)(HC) wherein it was held that no late filing fee could be levied for processing of statement u/s 200A (1) for the period before 01.06.2015. In light of the said decision, the Tribunal held in favor of the Assessee that before 01.06.2015, there being no enabling provision for raising a demand in respect of levy of fees u/s 234E of the Act, no such levy could have been effected. (AY.2013-14,2014-15)