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Tax matters that crop up for complete lack of jurisdiction are better fought before jurisdictional Courts as even delay in approaching the Courts cannot be relied upon as a ground to deny the relief vide [2022] 443 ITR 267 (Ker).
In this case the taxpayer received demands for late fee u/s 234E for failure to submit statement of tax deducted at source for pre-June 2015 period.  He did not appeal such demands so these in effect became final and due. He challenged such demands before the jurisdictional High Court raising ground of lack of jurisdiction after this very Court in the earlier held such levy to be prospectivehaving come into effect only from June 1, 2015. The opposition by the revenue on the twin grounds of delay in approaching Courts and existence of alternative remedy failed. 

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