Dismissing the petition the Court held that, The provisions of the Act imposing a fee for delayed filing of the statement of tax deducted at source are not ultra vires the provisions of the Constitution. It is a well-known principle of interpretation that the court must lean towards constitutionality of a statutory provision; and if two interpretations are possible, one for and one against the constitutionality of a legal provision, courts invariably choose the one upholding the constitutionality of the provisions.