Allowing the petition the Court held  that the Department had imposed the late fee only under section 234E of the Act for the assessment years 2012-13, 2013-14, 2014-15. However, section 200A(1)(c) of the Act was not introduced during the assessment years in question. In the absence of any provisions under section 200A of the Act, when processing the application for tax deducted at source under section 200A, no late fee could be imposed under section 234E. The levy was not valid.(AY.2012-12 to 2014-15)