Rated 4.9/5 by 312+ Chennai clientsZero penalty record across all filings24-hour response · WhatsApp-first supportOffices: Maduravoyal, Nerkundram & Nolambur (upcoming)15+ years of expert tax & compliance consulting500+ active clients across 243 Chennai areasRated 4.9/5 by 312+ Chennai clientsZero penalty record across all filings24-hour response · WhatsApp-first supportOffices: Maduravoyal, Nerkundram & Nolambur (upcoming)15+ years of expert tax & compliance consulting500+ active clients across 243 Chennai areas
Greams Road healthcare cluster anchored by apollo businesses · TDS Notice Reply specialists

TDS Notice Reply in Greams Road, Chennai

Professional TDS Notice Reply for Greams Road businesses near Apollo Hospital Greams Road — handled by a qualified, in-house team

for Greams Road businesses balancing growth ambitions with tight statutory compliance with on-time portal submission and full statutory reconciliation. Call 9566-068-468.

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Quick Answer

How does challan correction under OLTAS work in Greams Road, Chennai?

Where a TDS challan was paid with a wrong TAN, AY, Section code or major head (200/400), the deductor approaches the assessing bank within 7 days (minor head) or the jurisdictional AO TDS within 90 days (TAN / AY / Section). The AO passes a correction order under OLTAS rules (CBDT Circular 11/2011). Corrected challan reflects in Form 26AS within 5-10 working days; the Online Correction C-1 / C-2 is then filed on TRACES to consume the corrected challan into the deductee statement.

Transparent Pricing

TDS Notice Reply in Greams Road — Plans & Pricing

Fixed fees · Zero hidden charges · Call 9566-068-468 for a custom quote.

MonthlyAnnualSave 2 Months
Basic Reply
Section 200A intimation reply
₹2,500/per notice

  • Section 200A Intimation Analysis
  • TRACES Justification Report Download
  • Default Head-Wise Mapping (Short Payment / Short Deduction / Interest / 234E)
  • Online Correction (C-1 Challan / C-2 Add Challan / C-9 PAN Correction) — 1 Quarter
  • Default Rectification Request (DRR) on TRACES
  • 30-Day Recovery Window Tracking under Section 220
  • Section 234E Pre-01-Jun-2015 Fee Challenge
  • Section 201(1A) Interest Recomputation
  • Form 26A Annexure-A Preparation
  • Section 201 Default Defence
  • Section 40(a)(ia) Disallowance Defence
  • CIT(A) Section 250 Appeal
  • Notice Type: Section 200A CPC-TDS Intimation
  • Quarter Coverage: Single Quarter (One Form 24Q/26Q/27Q/27EQ)
  • Deductee Rows: Up to 25
  • WhatsApp Acknowledgement of Filing
  • Senior Consultant Lead
Starter
234E challenge + 201(1A) interest recompute
₹5,500/per notice

  • Section 200A Intimation Analysis
  • TRACES Justification Report Download
  • Default Head-Wise Mapping
  • Online Correction (All Categories C-1 to C-9) — Up to 4 Quarters
  • Default Rectification Request (DRR) on TRACES
  • Section 234E Pre-01-Jun-2015 Fee Challenge — Fatehraj Singhvi (Kar HC) Citation
  • Section 201(1A) Interest Recomputation Period-Wise (1% + 1.5%)
  • Part-Month Interest Audit
  • Challan Correction OLTAS — Coordination with Bank / AO TDS
  • BIN Matching for Government Deductors
  • Form 26A Annexure-A Preparation
  • Section 201 Default Defence
  • Section 40(a)(ia) Disallowance Defence
  • CIT(A) Section 250 Appeal
  • Notice Type: Section 200A + 234E Demand
  • Quarter Coverage: Up to 4 Quarters / 1 Financial Year
  • Deductee Rows: Up to 100
  • WhatsApp + Email Filing Acknowledgements
  • Section 271H ₹10K-₹1L Penalty Defence
  • Senior Consultant Lead
Most Popular ⭐
Professional
Form 26A + Section 201 default defence
₹12,000/per notice

  • Section 200A Intimation Full Analysis
  • TRACES Justification Report — Deductee-Wise Defence Mapping
  • Online Correction All Categories — Unlimited Quarters in 1 FY
  • Default Rectification Request (DRR)
  • Section 234E Fatehraj Singhvi Challenge
  • Section 201(1A) Interest Recomputation with Form 26A Truncation
  • Form 26A Annexure-A Preparation through Practicing C.A.
  • Online Filing of Form 26A on TRACES (Deductor + C.A. Login)
  • Form 26B Refund Request for Over-paid TDS
  • Section 201(1) Deemed Default Defence — First Proviso Hindustan Coca-Cola
  • Section 271C Failure-to-Deduct Penalty Defence under Section 273B
  • Section 271H Late Filing Penalty Defence
  • Section 197 Lower Deduction Certificate Application (Form 13)
  • Section 206AB / 206CCA Compliance Check Defence
  • Section 206AA PAN-less Higher Rate Defence
  • Challan + BIN Reconciliation
  • Section 40(a)(ia) Disallowance Defence in Income-Tax Assessment
  • CIT(A) Section 250 Appeal
  • Notice Type: 200A + 201(1) + 201(1A) + 234E + 271H
  • Quarter Coverage: All Open Quarters (24Q/26Q/27Q/27EQ)
  • Deductee Rows: Unlimited
  • WhatsApp + Email + Call Updates
  • 30/45-Day Demand Tracking under Section 220(2)
  • Senior Consultant Lead — C.A. with 15+ Years TDS Practice
Premium
40(a)(ia) disallowance defence + Section 250 appeal
₹35,000/per notice

  • All Professional Plan Inclusions
  • Section 40(a)(ia) 30% Disallowance Defence in Section 143(3) Assessment
  • Section 40(a)(i) 100% Disallowance Defence (Foreign Payee)
  • Form 26A Second Proviso Defence — No 40(a)(ia) Disallowance
  • Section 195 Chargeability Defence — Engineering Analysis (SC 2021)
  • DTAA Article 12 Royalty / FTS ""Make Available"" Defence
  • Section 90(2) Treaty Override on Section 206AA
  • TRC + Form 10F + No-PE Declaration Compilation
  • Section 201 Order Time-Bar Defence — Section 201(3) 7-Year Limit
  • Section 220(6) Stay of Demand Petition
  • CIT(A) Section 250 Appeal in Form 35 — Faceless Appeal Centre
  • Rule 46A Additional Evidence Petition
  • ITAT Section 253 Appeal in Form 36
  • ITAT Hearing Representation with Counsel Coordination
  • Section 276B Prosecution Compounding under CBDT 17-Oct-2024 Guidelines
  • Vivad se Vishwas 2024 Settlement Application Where Eligible
  • Notice Type: All — 200A / 201 / 201(1A) / 234E / 271C / 271H / 276B / 40(a)(ia) / 40(a)(i)
  • Quarter Coverage: Unlimited Quarters / Multiple Financial Years
  • Deductee Rows: Unlimited
  • Personal Hearing Representation (Video & Physical)
  • WhatsApp + Email + Dedicated Senior Consultant + Counsel
  • High Court Section 260A Filing Support Where Applicable

Swipe to see all plans

Prices exclude GST. For enterprise pricing, call 9566-068-468.

Why FilingPro?

Why Greams Road Clients Choose FilingPro

Expert TDS Notice Reply in Greams Road — qualified professionals, 15+ years experience, zero-penalty track record.

Section 40(a)(ia) Second Proviso Defence

Once Form 26A is accepted on TRACES, the second proviso to Section 40(a)(ia) is invoked in the deductor's Section 143(3) assessment to defeat the 30% expense disallowance — Form 26A pulls double duty for Greams Road clients.

Online Correction All Categories C-1 to C-9

Our team handles every Online Correction category — C-1 challan correction, C-2 add challan, C-3 personal info, C-4 salary detail, C-5 deductee detail, C-6 row movement, C-7 PAN-Aadhaar, C-8 add challan with row, C-9 PAN correction. Conso File downloaded, corrected, validated through FVU and uploaded same day.

Default Rectification Request (DRR) for CPC Errors

Where the underlying statement is correct but CPC-TDS has wrongly raised default — challan paid but not visible due to OLTAS / BIN issue, double-counted interest — Default Rectification Request is raised on TRACES; CPC-TDS Ghaziabad responds in 30-45 days.

Section 195 Engineering Analysis Defence

For Section 195 short-deduction on software / cloud / SaaS payments to non-residents, Engineering Analysis Centre of Excellence v. CIT [2021] 432 ITR 471 (SC) is invoked — payment is not royalty under DTAA Article 12, no TDS obligation, no 201 default, no 40(a)(i) disallowance.

Section 206AB Compliance Check Defence

Short-deduction defaults under Section 206AB are defended by producing the dated Compliance Check screenshot from the Reporting Portal proving the deductee was NOT a specified person at the time of payment. Status snapshot is the dispositive evidence.

Section 276B Prosecution Compounding

Where non-deposit of TDS exceeds ₹25 lakh threshold triggering compulsory prosecution under Section 276B, we coordinate full deposit of TDS + 1.5% interest, file compounding application under the latest CBDT Compounding Guidelines dated 17-Oct-2024 — criminal proceedings closed before trial commencement.

Key Benefits

What Greams Road Clients Get

Every TDS Notice Reply engagement delivers measurable, guaranteed outcomes — expert professionals, on time, every time.

Section 40(a)(i) 100% Disallowance Defeated for Foreign Payments
For non-resident payments, Section 195 chargeability is challenged through DTAA Article 12 "make available" test, Engineering Analysis (SC 2021) for software, GE India Technology (SC 2010) on chargeability — entire 100% Section 40(a)(i) disallowance dropped.
Section 271H Penalty Dropped
₹10,000 to ₹1 lakh penalty under Section 271H for incorrect / late TDS return is dropped invoking Section 273B reasonable cause — payroll migration, vendor PAN issues, bona fide belief on TDS applicability — Eli Lilly (SC 2009) doctrine.
Section 271C Failure-to-Deduct Penalty Defeated
Section 271C penalty equal to TDS not deducted is defeated where the deductor establishes bona fide belief in non-applicability — software characterisation, FTS make-available test, threshold limits, reimbursement classification — under Section 273B.
Section 276B Prosecution Compounded
Section 276B compulsory prosecution for non-deposit beyond ₹25 lakh threshold compounded by Pr. CCIT — TDS + 1.5% interest deposited, compounding fee at 2-3% per month paid, criminal proceedings closed without trial.
Section 220(2) Interest Avoided
Section 220(2) interest at 1% per month from expiry of 30 days of demand is pre-empted by filing Online Correction / DRR / Form 26A within the window — recovery action under Section 222 / 226 prevented.
Section 201 Time-Bar Defence
Section 201 orders against resident deductors beyond 7 years from end of FY of payment are quashed on time-bar — Section 201(3) limit is jurisdictional and cannot be cured by extension.
Comparison

Section 200A Intimation vs Section 201 Default Order

Why this matters here — In Greams Road, the business activity radiating outward from Apollo Hospital Greams Road and nearby commercial pockets; with quick access via Greams Road Bus Stop and feeder routes connecting Greams Road to the rest of Chennai.

AspectSection 200A IntimationSection 201 Default Order
Limitation periodMust be issued within one year from the end of the financial year in which the statement is filed per the proviso to Section 200A(1)Seven years from the end of the financial year in which payment is made or credit is given, per Section 201(3) as substituted by Finance (No. 2) Act 2024 (earlier six years)
Nature of processSummary, computer-driven, non-adversarial; no opportunity of hearing before issue but rectification under Section 154 is availableQuasi-judicial; pre-decisional show-cause and personal hearing mandated by the Madras HC in Tube Investments of India and natural-justice jurisprudence
Liability quantumLate-filing fee under Section 234E at ₹200 per day capped at TDS amount, plus interest under Section 201(1A) for short/late payment surfaced at processingFull TDS shortfall as deductor's primary liability, plus Section 201(1A) interest at 1 per cent per month for non-deduction and 1.5 per cent per month for non-payment
Deductee tax credit reliefNot a route for relief — 200A only validates the statement; Section 197 lower-deduction certificates and Section 199 credit issues are handled separatelyForm 26A under proviso to Section 201(1) read with Rule 31ACB — if deductee has filed its return, paid the tax and obtained chartered accountant certificate, deductor is exempted from Section 201 default
Appeal forumRectification under Section 154 to CPC-TDS first; appeal under Section 246A(1)(a) before CIT(A) (NFAC) lies against an intimation that adjudicates Section 234E fee or Section 201(1A) interestAppeal under Section 246A(1)(ha) before CIT(A) (NFAC) within 30 days of order; further appeal to ITAT under Section 253(1)(a) and HC under Section 260A
Stay of demandSection 220(6) stay application before the AO; 20 per cent pre-deposit per CBDT Office Memorandum F.No.404/72/93-ITCC dated 29 Feb 2016 is the working benchmarkStay before the CIT(A) under inherent powers (Asahi India Safety Glass ratio) or before ITAT under Section 254(2A); writ to Madras HC where serious prejudice is shown
Penalty exposureSection 234E late-filing fee operates here; Section 271H penalty for non-filing or inaccurate statement is initiated separately if delay exceeds one year or particulars are wrongPenalty under Section 271C (failure to deduct) at 100 per cent of TDS, under Section 271CA (failure to collect) and prosecution under Section 276B (failure to deposit) — separate proceedings
Reasonable cause defenceSection 273B reasonable-cause defence is generally not available against Section 234E fee — the fee is automatic per Karnataka HC in Fatheraj Singhvi and Madras HC follow-up rulingsSection 273B is a complete defence against Sections 271C and 271CA penalties; bonafide interpretation, certified opinion or vendor's Form 26A operates to negate mens rea
Strategic response postureRapid reconciliation, correction statement (Form 27A) within the 30-day intimation window, Section 154 rectification for system errors; 234E challenge route is largely foreclosedDetailed factual reply to Section 201 show-cause, Form 26A from deductees where possible, written submissions citing GE Technology Centre and Hindustan Coca-Cola; preserve appellate record
Statutory anchorComputer-processed intimation generated by CPC-TDS under Section 200A(1) of the Income Tax Act 1961 after processing the TDS statement filed under Section 200(3)Quasi-judicial order passed by the jurisdictional Assessing Officer (TDS) under Section 201(1) read with Section 201(1A) treating the deductor as an assessee-in-default
TriggerArithmetical errors, incorrect claim apparent from the statement, short payment as per challan-statement match, or late-filing fee under Section 234E surfaced during automated processingFailure to deduct, short deduction, failure to deposit after deduction, or wrong-section deduction noticed by the AO after enquiry under Section 201(1) read with Rule 31A reconciliation
Issuing authorityCentralised Processing Cell-TDS at Vaishali, Ghaziabad, operating as the prescribed authority under the Centralised Processing of Statements Scheme 2013Jurisdictional Assessing Officer (TDS) — for Chennai deductors this is the ITO/ACIT (TDS) wards at Nungambakkam, after issuing a Section 201 show-cause notice with opportunity of hearing
Documents Required

Documents for TDS Notice Reply

Share documents via WhatsApp to 9566-068-468. No office visit required for Greams Road clients.

Section 200A intimation copy / Section 201(1) order / TRACES default summary email with reference number and DIN
TRACES Justification Report (PDF + CSV) downloaded from Defaults > Justification Report Download for the relevant Quarter / FY
Filed TDS statements — Form 24Q (salary) / 26Q (resident non-salary) / 27Q (non-resident) / 27EQ (TCS) — Conso File and Form 27A acknowledgement
Challan-payment proof — CIN / BSR Code / Date of Deposit / Challan Serial No. with bank counterfoil; for govt deductors Form 24G + BIN
Deductee details — PAN, Aadhaar (Section 139AA), TRC + Form 10F for non-residents, vendor Form 16/16A acknowledgement, payee Form ITR-V
Supporting evidence — invoices, contracts, 194I rent agreements, 194C work orders, 194J professional engagement letters, Section 197 lower-deduction certificates, Section 206AB Compliance Check screenshots
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Statutory Deadlines

Compliance deadlines that matter

Miss any of these and the next consequence kicks in automatically.

Deadlines in this neighbourhood — In Greams Road, the cluster of healthcare, hospitality, pharmaceutical businesses that defines Greams Road's commercial fabric.

Trigger eventDaysFormConsequence
Service of Section 200A intimation by CPC-TDS30 daysOnline response on TRACESSection 220(2) interest at one per cent per month accrues from day thirty-one onward
Service of Section 201(1) order treating deductor as assessee in default30 daysForm 35 first appealRight of first appeal under Section 246A lapses subject to delay condonation
Filing of corrected TDS statement to extinguish short-deduction default365 daysConso File correction through TRACESSection 271H(3) immunity window closes on completion of one year from due date
Outer limit for passing Section 201(1) order2555 daysNot applicableLimitation under Section 201(3) bars passing of order beyond seven financial years
Receipt of Section 200A intimation by email or post30 daysOnline Correction / DRR on TRACESDemand becomes recoverable under Section 220(1) with Section 220(2) interest at 1% per month and Section 221 penalty risk
Receipt of Section 201(1) deemed-default order by email30 daysForm 35 CIT(A) appeal / Section 220(6) stay applicationSection 220(2) interest at 1% per month accrues; PAN-level recovery tag activates on TRACES blocking refunds
Section 234E late-fee crystallisation on Section 200(3) due-date breachOn due dateForm 26Q / 24Q / 27Q / 27EQ — file immediately on defaultFee accrues at ₹200/day from the due-date until statement filed; capped at TDS amount; Section 271H penalty notice within 12 months
Filing Section 220(6) stay application pending first appeal30 daysStay application to Assessing OfficerTwenty per cent pre-deposit norm under Instruction 1914 applies absent stay

Deadline pressure points we see in Greams Road: On the ground in Greams Road, for Greams Road businesses balancing growth ambitions with tight statutory compliance.

Forms Library

Forms used in this engagement

Form 26ACertificate from accountant under first proviso to Section 201(1)

Certifies that the deductee has filed return, included the receipt and paid the tax, thereby extinguishing the deductor's deemed-default exposure.

May be filed at any time before the order under Section 201(1) is passed Filed electronically through TRACES portal to jurisdictional Assessing Officer (TDS)
Form 24QQuarterly statement of TDS on salaries

Carries deductee-wise particulars of tax deducted from salary payments under Section 192, with Annexure II in the fourth quarter for salary computation.

Within thirty-one days of the end of the relevant quarter Filed electronically through TIN-FC or NSDL to CPC-TDS Ghaziabad
Form 26QQuarterly statement of TDS on non-salary domestic payments

Carries deductee-wise particulars of tax deducted on payments to residents other than salaries — Sections 194 to 194T as applicable.

Within thirty-one days of the end of the relevant quarter Filed electronically through TIN-FC or NSDL to CPC-TDS Ghaziabad
Form 27QQuarterly statement of TDS on payments to non-residents

Carries deductee-wise particulars of tax deducted on payments to non-residents under Section 195, with country code, residential status and DTAA rate fields.

Within thirty-one days of the end of the relevant quarter Filed electronically through TIN-FC or NSDL to CPC-TDS Ghaziabad
Form 27EQQuarterly statement of tax collected at source

Carries collectee-wise particulars of tax collected under Section 206C, covering scrap, timber, motor vehicles, foreign remittance and overseas tour package items.

Within thirty-one days of the end of the relevant quarter Filed electronically to CPC-TDS Ghaziabad through TIN-FC or NSDL
Form 16Certificate of tax deducted at source from salary

Issued to salaried employees evidencing tax deducted under Section 192, carrying Part A from TRACES and Part B with detailed salary computation.

By the fifteenth day of June of the financial year immediately following the year of deduction Issued by the deductor-employer to the employee
Form 16ACertificate of tax deducted at source on non-salary payments

Issued to deductees evidencing tax deducted on payments other than salary, downloaded from TRACES with verifiable certificate-number for credit reconciliation.

Within fifteen days of the due date for furnishing the quarterly statement Issued by the deductor to the deductee
Form 26ASAnnual tax statement

Consolidated tax credit statement reflecting tax deducted, tax collected, advance and self-assessment tax paid, refunds and high-value transactions, accessed via the e-filing portal.

Continuously updated; reconciled with quarterly TDS statements Generated by the Income-tax Department; viewed by deductee

TDS Notice Reply in Greams Road, Chennai 600006

Records we prepare for Greams Road carry the geo-zone 600xx tag and coordinates 13.0596, 80.2517, which map each submission back to this locality. Statutory correspondence for Greams Road businesses routes through the Mylapore Division, so we align every TDS Notice Reply engagement to that jurisdiction from the start. Because PIN 600006 sits inside the Chennai South jurisdiction, the handling office for Greams Road stays consistent across years, which matters when filings or approvals span cycles. We keep a cycle-by-cycle record of how the Mylapore Division of the Chennai South handles Greams Road filings and approvals.

Working in Greams Road brings a logistical edge: proximity to Apollo Pharmacy HQ and the Greams Road Bus Stop corridor keeps physical document handling fast. Freight and foot traffic from the Greams Road Bus Stop hub pull steady daily commerce through Greams Road, so there is rarely a quiet filing month in this healthcare cluster anchored by apollo pocket. Commercial activity in Greams Road runs high, so TDS Notice Reply volumes scale through peak months and we staff the Greams Road desk accordingly. Greams Road sustains a high flow of commerce for a healthcare cluster anchored by apollo locality, and that flow is the raw material for the TDS Notice Reply files we close here.

The business mix in Greams Road centres on hospitality, and that sector carries its own TDS Notice Reply quirks we plan for in advance. TDS Notice Reply for hospitality businesses in Greams Road hinges on getting the sector's recurring entries right the first time. For a hospitality business in Greams Road, the TDS Notice Reply scope is rarely generic; we tailor the checklist to how that sector actually transacts. The hospitality firms we serve in Greams Road value a TDS Notice Reply partner who already understands their sector's compliance rhythm.

Turnaround for Greams Road TDS Notice Reply is deterministic — fixed fee, a scoped timeline, and a same-business-day acknowledgement once filed. The qualified-review step on every Greams Road TDS Notice Reply file is where errors get caught before they reach the portal. Document intake for Greams Road clients runs over WhatsApp, so there is no office visit and no paper shuffle for a TDS Notice Reply engagement. Fixed-fee scoping means a Greams Road business knows the TDS Notice Reply cost up front, with no surprise additions mid-engagement.

Proximity to Thousand Lights means a Greams Road engagement can extend across the locality cluster with no change in cadence. Serving Greams Road and Thousand Lights from one team keeps TDS Notice Reply turnaround identical across the cluster. From the same Greams Road team we also serve Thousand Lights and other nearby localities without re-onboarding clients. A client relocating between Greams Road and Thousand Lights keeps the same TDS Notice Reply file and the same team.

Sector signals in Greams Road — seasonal pharmaceutical swings and peak-period volumes — shape how we schedule TDS Notice Reply work. Common patterns in the Mylapore Division give Greams Road businesses an early-warning map we use to pre-empt TDS Notice Reply issues. The TDS Notice Reply mistakes we see most in Greams Road are avoidable with disciplined intake, which our checklist enforces. Recurring gaps in Greams Road pharmaceutical records are the first thing our TDS Notice Reply review closes out.

Shifting principal place of business to Greams Road means updating jurisdiction to the Chennai South, and we manage the paperwork end-to-end. We onboard new Greams Road entities onto a TDS Notice Reply cadence that is audit-ready from the very first cycle. A startup setting up near Anna Salai in Greams Road gets a TDS Notice Reply foundation built for the Mylapore Division from day one. Relocating a registered office into Greams Road (PIN 600006) changes the assessing division, and we handle that TDS Notice Reply transition cleanly.

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Expert Guide

TDS Notice Reply in Greams Road — Complete Guide

TDS Notice Reply for Greams Road (600006) deductors is handled end-to-end at FilingPro — Section 200A CPC-TDS intimation, Section 201(1) deemed-default order, Section 201(1A) interest at 1% / 1.5% per month, Section 234E ₹200/day late fee and Section 271H penalty. The TRACES Justification Report is downloaded on day one, every default head — short payment, short deduction, interest and fee — is mapped to a defence, and the appropriate remedy (Online Correction C-1 to C-9, Default Rectification Request, Form 26A Annexure-A, or full reply with case law) is filed within the 30-day Section 220 recovery window.

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Qualified professionals handle your TDS Notice Reply in Greams Road. WhatsApp documents — we begin within 24 hours. From ₹2,500/per-notice. Free consultation.
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From ₹2,500/per-notice
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Key Facts — TDS Notice Reply in Greams Road
Section 200A intimation reply with line-by-line Justification Report mapping — short payment, short deduction, 201(1A) interest and 234E fee defended on facts
Online Correction filed on TRACES across all categories C-1 through C-9 — challan tagging, PAN correction, deductee row movement, salary detail correction in 24Q Annexure II
Section 234E ₹200 per day late fee challenged on Fatehraj Singhvi (Karnataka HC 2016) for pre-01-Jun-2015 quarters; period-wise computation audited for post-01-Jun-2015 levies
Section 201(1) deemed-default order defended through Form 26A Annexure-A under first proviso — Hindustan Coca-Cola SC 2007 codified relief; default head reduced to NIL on TRACES
Section 201(1A) interest recomputed manually with Form 26A truncation up to deductee return-filing date — saves 1% per month for the post-return period
Section 40(a)(ia) 30% expense disallowance in Section 143(3) assessment defended through second proviso — Form 26A relief extends to business-income computation
Section 195 / 206AA / 90(2) defence for non-resident TDS — DTAA Article 12 "make available" test, Engineering Analysis (SC 2021) for software, TRC + Form 10F + No-PE declaration
Section 271H ₹10K-₹1L penalty for late / incorrect TDS return defended under Section 271H(3) immunity and Section 273B reasonable cause — Eli Lilly SC 2009 doctrine
Section 276B prosecution for non-deposit of TDS — compounding application under CBDT Guidelines dated 17-Oct-2024 with full payment of TDS + 1.5% interest
CIT(A) Section 250 appeal in Form 35 against Section 201 / 271C orders, Section 220(6) stay of demand, ITAT Section 253 representation — Vivad se Vishwas 2024 evaluated
People Also Ask — TDS Notice Reply in Greams Road
What is the time limit to reply to a Section 200A intimation?
No separate reply window — but the demand becomes recoverable under Section 220(1) after 30 days of service. Online Correction or Default Rectification Request must be filed within 30 days to avoid recovery, interest under Section 220(2) at 1% per month and penalty under Section 221.
How do I download the TRACES Justification Report?
Login to www.tdscpc.gov.in as Deductor > Defaults > Justification Report Download > select FY, Quarter and Form Type > submit request > download from Requested Downloads after 24 hours. Both PDF (summary) and CSV (deductee-wise) versions are available — both are required for a complete defence.
Does Form 26A wipe out the entire TDS demand?
Form 26A wipes out the principal short-deduction default under Section 201(1) but interest under Section 201(1A)(i) at 1% per month from the date the tax was deductible up to the date the deductee filed his return is still payable by the deductor. The 1.5% interest under 201(1A)(ii) is irrelevant since no deduction occurred.
Can Section 234E fee be challenged for periods before 01-Jun-2015?
Yes — the Karnataka High Court in Fatehraj Singhvi & Ors v. UoI [2016] 73 taxmann.com 252 held that Section 200A(1)(c) authorising 234E adjustment was inserted only w.e.f. 01-Jun-2015 by Finance Act 2015; pre-amendment 234E levies through Section 200A intimation are ultra vires. Multiple ITAT benches (Mumbai, Pune, Chennai) follow this ratio.
What is the difference between Online Correction and Default Rectification Request?
Online Correction (TRACES > Defaults > Request for Correction) is filed by the deductor to amend the TDS statement — challan tagging, PAN correction, deductee row movement, etc. — across categories C-1 to C-9. Default Rectification Request (DRR) is raised against an erroneous default flagged by CPC-TDS where the underlying statement is correct (e.g. challan paid but not visible due to BIN / OLTAS issue).
What is the limitation period for a Section 201 order?
Section 201(3) (substituted by Finance (No. 2) Act 2014) prescribes 7 years from the end of the FY in which payment is made / credit is given for resident payees. For non-resident payees there is no statutory time-limit; courts have read in a reasonable period (Vodafone Idea / Mahindra Holidays line). Time-barred 201 orders are quashable in writ.
What is Form 26A and how do I obtain it?

Form 26A is a CA certificate under Rule 31ACB confirming that the deductee has filed return and paid tax on the income on which you failed to deduct TDS. Obtain from deductee's CA, upload on TRACES; this drops your primary Section 201 liability.

Can I rectify a Section 200A intimation?

Yes. File a rectification application under Section 154 before CPC-TDS within four years from the end of the financial year in which the intimation is issued. Common rectifiable errors include challan mismatches, deductee-PAN errors, and interest computation discrepancies.

What is the time limit for Section 200A intimation?

The proviso to Section 200A(1) requires the intimation to be issued within one year from the end of the financial year in which the TDS statement is filed. Intimations beyond this period are without statutory authority and may be challenged.

Is Section 206AA 20 per cent rate automatic where deductee has no PAN?

Yes, but with carve-outs. Section 206AA mandates 20 per cent TDS where deductee has no PAN. However Rule 37BC (inserted 24 June 2016) provides relief for non-residents with TRC, Form 10F and alternative identification details; DTAA rate then applies despite no PAN.

What is the Section 273B reasonable-cause defence?

Section 273B is a complete defence against most penalty provisions including Sections 271C, 271CA and 271H. Bona fide reliance on opinion, vendor's Form 26A, prolonged illness of finance officer, software lockouts, vendor disputes — all may constitute reasonable cause.

How do I respond to a TRACES default notice in Chennai?

Log in to TRACES, view the default summary, file correction statement for system-level defects, file Section 154 rectification before CPC-TDS for processing errors, file Form 26A for deductee-side relief, and engage a Chennai tax lawyer for Section 201 show-cause replies.

What Greams Road clients want to know before signing: On the ground in Greams Road, in the healthcare cluster anchored by apollo micro-market of Greams Road.

Expert Guide

A complete walkthrough — Tds Notice Reply

Reading this guide locally — In Greams Road, on the Thousand Lights-Alwarpet corridor that passes through Greams Road.

What is a TDS notice and the architecture of TDS enforcement

TRACES portal and the Justification Report

The TDS Reconciliation Analysis and Correction Enabling System (TRACES) is the operational interface through which CPC-TDS communicates with deductors. Sub-rule (2) of Rule 31A of the Income Tax Rules 1962 provides that every default identified during processing is recorded on TRACES with a downloadable Justification Report — a PDF and CSV deliverable that lists row-wise the challan, deductee PAN, section, deduction-amount, default-head and amount-in-default. The Justification Report carries indicative computations only; the binding figures are those in the Section 200A intimation and the consequential demand on the TRACES dashboard. The TRACES architecture follows the OECD Forum on Tax Administration's 2014 design template on digital-by-default tax-payer-services, mirrored in similar withholding-platforms in the United Kingdom (HMRC RTI) and Australia (ATO Single Touch Payroll).

Comparative jurisprudence — India versus OECD

The Indian TDS-default framework is more punitive than comparable OECD jurisdictions on the interest-rate and disallowance dimensions. Section 201(1A) charges interest at 1% per month on non-deduction and 1.5% per month on deduction-not-deposited — i.e. an effective annualised 12% and 18%. The OECD International VAT/GST Guidelines do not directly cover income-tax withholding, but the comparable HMRC PAYE-default interest in the United Kingdom is benchmarked against the Bank of England base rate plus 2.5 percentage points, currently in the 7-8% range. Australia's ATO general interest charge sits at 11.36%. The disallowance dimension is uniquely Indian — Section 40(a)(ia) disallows 30% of the expenditure (and 100% for non-resident payments under 40(a)(i)) in the deductor's own income, with no comparable provision in major OECD systems where withholding default is treated purely as a separate collection matter.

Conceptual origin of TDS as pay-as-you-earn

The Tax Deduction at Source mechanism in India under Chapter XVII-B of the Income Tax Act 1961 implements what the OECD framework calls a pay-as-you-earn collection design. It is to be noted that the policy goal traces to the Direct Taxes Enquiry Committee 1971 (Wanchoo Committee) recommendation that revenue collection be advanced to the point of accrual rather than the point of assessment, reducing tax arrears and broadening the information base. The Comptroller and Auditor General's 2017 performance audit on TDS administration observed that approximately 36% of direct-tax revenue is now collected at source, against an OECD-area average of roughly 60% for income subject to withholding. A TDS notice therefore performs a dual function — it is both a revenue-recovery instrument addressed to the deductor as the assessee-in-default under Section 201, and an information-correction instrument under Section 200A reconciling the deductor return with deductee credit claims in Form 26AS.

TRACES default summary mechanics and the Justification Report

Conso File and Online Correction workflow

The Conso File (Consolidated File) is the deductor's quarterly statement as accepted on TRACES, downloadable for the purpose of corrections. The workflow is — first, download the Conso File and the Justification Report, second, identify the row-level mismatches, third, prepare a correction statement using NSDL's Return Preparation Utility, fourth, validate through the File Validation Utility, fifth, upload through the Online Correction option on TRACES. The correction-types C-1 to C-9 are addressable through this workflow except for fundamental challan-replacement which requires C-3 challan-addition. Sub-rule (5A) of Rule 31A provides the procedural anchor.

Default Rectification Request mechanism

Where the Justification Report contains computational errors of the CPC-TDS — interest computed on wrong principal, fee computed for a period covered by CBDT extension, double-counting of the same default across heads — the Default Rectification Request is filed through TRACES. The request requires a written explanation supported by computation, challan copies and any CBDT instruction relied upon. The processing timeline is typically four to eight weeks. Where the rectification is rejected or partially accepted, the next escalation is the Section 154 application before the Assessing Officer (TDS) for the residual contested portion, followed by Section 246A appeal.

Comparing TRACES with international peer systems

The TRACES design corresponds to the OECD Forum on Tax Administration's 2014 recommendations on digital-by-default tax-administration. Peer systems include HMRC's PAYE Real Time Information in the United Kingdom — though PAYE RTI is on-payment-event reporting rather than quarterly statement reconciliation — and the ATO's Single Touch Payroll in Australia. The Tax Administration of New Zealand operates PAYE through Inland Revenue's myIR portal. The Brazilian eSocial system is closest to the TRACES quarterly-reconciliation design. The OECD International Compliance Assurance Programme has published comparative material though no formal benchmarking on withholding-default frameworks specifically.

Form 16 and Form 16A reconciliation with 26AS and AIS

Statutory basis under Rule 31

Sub-rule (1) of Rule 31 prescribes Form 16 for salary deduction certificates under Section 192 (Part A from TRACES, Part B from the employer), Form 16A for non-salary deduction certificates under Sections 193 to 196D, and Form 16B for Section 194-IA certificates on immovable-property purchase. Form 16C for 194-IB rent and Form 16D for 194M certain payments. The timelines under Rule 31(3) are — Form 16 by 15-Jun of the subsequent assessment year, Form 16A within fifteen days of the due date for the quarterly statement. Failure invites Section 272A(2)(g) penalty at ₹500 per day capped at the TDS amount.

Form 26AS — single-window credit statement

Form 26AS, expanded post Finance Act 2020 under Rule 114-I, aggregates — TDS credit from deductor statements, TCS credit from collector statements, advance-tax and self-assessment-tax challans, refund issued, high-value transactions (now migrated to AIS), specified financial transactions and DTAA-relief claims. CBDT Notification 30/2020 expanded the scope. The 26AS feeds the deductee's return through the pre-fill mechanism. Mismatches between Form 16A and Form 26AS commonly arise on PAN-mapping (PAN typo at the deductor end), section-mismatch (deducted under wrong section), and challan-mapping issues. The deductee's reconciliation duty is now operationalised through AIS-Annual Information Statement.

Annual Information Statement and CBDT Circular 8/2021

The Annual Information Statement (AIS) introduced by CBDT Circular 8/2021 dated 26-May-2021 and operationalised through the Income Tax Department's compliance portal provides a comprehensive view of the taxpayer's financial transactions — including those reported by deductors, collectors, banks, mutual funds, registrars, GST authorities and other reporting entities. AIS supersedes the limited 26AS coverage on high-value transactions. The Taxpayer Information Summary (TIS) is the simplified subset. The OECD's pre-filled-return design template — operationalised in Denmark, Norway and Singapore — is the comparable international architecture. The AIS feedback mechanism enables the taxpayer to flag disputed entries, prompting reporter-side reconciliation.

Section 154 rectification of TDS orders and intimations

Appellate remedy if 154 rejected

Where the Section 154 application is rejected, the appellate route under Section 246A(1)(c) is available against the rectification order. The appeal can attack the underlying default order on merits as well as the rectification rejection. The Bombay HC in Indian Hume Pipe held that a rejection of 154 does not foreclose the underlying merits-challenge, and the Commissioner (Appeals) can entertain both. The procedural sequencing is — Section 200A intimation → Section 154 application → 154 order (acceptance / rejection) → Section 246A appeal to CIT(A) → Section 253 appeal to ITAT → Section 260A reference to HC. The limitation under 246A is 30 days from the order date.

Statutory scope and the four-year limit

Section 154 empowers the income-tax authority to rectify any order or intimation passed under the Act where there is a mistake apparent from the record. Sub-section (7) prescribes a four-year limit from the end of the financial year in which the order sought to be rectified was passed. The Supreme Court in T.S. Balaram ITO v Volkart Brothers held that a mistake apparent from the record is one that is obvious and patent — not one requiring extended argument. The application can be made by the assessee, or the authority may rectify on its own motion. The order on the application must be passed within six months from the end of the month in which the application is received.

Apparent mistake versus debatable question

The boundary between an apparent mistake (rectifiable under Section 154) and a debatable question of law (not rectifiable) has generated extensive jurisprudence. The Supreme Court in CIT v Hero Cycles held that a question of law on which two views are reasonably possible is not a mistake apparent from the record. Conversely, where the order ignores a binding precedent of the jurisdictional High Court or the Supreme Court delivered prior to the order date, the omission is rectifiable. The Madras HC in CIT v Maxopp Investment applied this distinction in a TDS-default context where a subsequent ruling on Section 194-I sub-heads was sought to be retrospectively applied.

What Greams Road clients usually ask next: On the ground in Greams Road, for Greams Road businesses balancing growth ambitions with tight statutory compliance.

Glossary

Plain-English glossary for this service

Section 276B Prosecution

Section 276B Prosecution is the prosecution provision applicable to a person who fails to pay to the credit of the Central Government the tax deducted under Chapter XVII-B. The offence is punishable with rigorous imprisonment for a term not less than three months but extendable to seven years, along with fine. Compounding is available under Section 279(2).

Section 279(2) Compounding

Section 279(2) Compounding is the discretionary administrative remedy under which the Principal Chief Commissioner or Chief Commissioner may compound an offence under Chapter XXII, including Section 276B, on payment of compounding charges as per the CBDT guidelines dated the seventeenth day of October 2024. Compounding shields the deductor from criminal trial.

Form 16 Issuance

Form 16 Issuance is the obligation of every employer to furnish to the employee, by the fifteenth day of June of the financial year following the year of deduction, a certificate of tax deducted from salary under Section 192. The certificate carries Part A from TRACES with TAN-verified deposit details and Part B with detailed salary computation.

Form 16A Issuance

Form 16A Issuance is the obligation of every deductor to furnish a certificate of tax deducted on non-salary payments to the deductee within fifteen days of the due date for furnishing the quarterly statement. The certificate is downloaded from TRACES with a verifiable certificate number which the deductee uses for reconciliation against Form 26AS.

Form 26AS Reconciliation

Form 26AS Reconciliation is the cross-verification exercise undertaken by the deductee to confirm that tax deducted on its receipts is reflected in the consolidated annual tax statement maintained under Rule 31AB and Section 285BB. Mismatches typically arise from incorrect permanent account number quoting or unfiled quarterly statements.

Annual Information Statement

Annual Information Statement is the consolidated information return maintained under Section 285BB and read with Rule 114-I, accessible on the e-filing portal. It carries a wider information set than Form 26AS — interest, dividend, securities transactions, foreign remittances — and is consumed by deductees during return preparation under Section 139.

Faceless Appeal Scheme

Faceless Appeal Scheme is the procedural scheme notified by the Central Board of Direct Taxes under Section 250(6B) and Section 250(6C), under which appeals before the Commissioner (Appeals) are heard by the National Faceless Appeal Centre at Delhi through electronic communication without personal hearing unless specifically requested.

Faceless Penalty Scheme

Faceless Penalty Scheme is the procedural scheme notified under Section 274(2A) and Section 274(2B) for faceless disposal of penalty proceedings under Section 271H, Section 271C and other listed provisions. The scheme places the proceeding before the National Faceless Penalty Centre with electronic show-cause and reply mechanics.

TIN-FC

TIN-FC is the Tax Information Network — Facilitation Centre operated by the Protean — formerly NSDL — for the physical or electronic intake of quarterly TDS statements, correction statements and Form 49B applications. The TIN-FC accepts FVU-validated files, generates a Token Acknowledgement and forwards data to CPC-TDS Ghaziabad.

Token Acknowledgement

Token Acknowledgement is the fifteen-digit receipt generated by the Tax Information Network upon successful intake of a quarterly TDS statement or correction filing at a TIN-FC or through the online upload route. The token is the operative reference for downstream Section 200A processing and is quoted in all correspondence with CPC-TDS Ghaziabad.

Digital Signature Certificate

Digital Signature Certificate is the cryptographic credential issued by a licensed Certifying Authority under the Information Technology Act 2000, used to digitally sign quarterly TDS statements, correction filings, Form 26A Annexure A and applications under Section 197. A Class III or Class III combined certificate is required for TRACES operations.

Section 197 Certificate

Section 197 Certificate is the certificate issued by the jurisdictional Assessing Officer (TDS) on application in Form 13, authorising the deductor to deduct tax at nil or lower rate where the recipient's estimated total tax liability for the year justifies such reduction. The certificate is prospective from the date of issue and quotes specific deductors and ceilings.

Cost of Non-Compliance

Real-world penalty exposure

Numerical examples showing tax + interest + penalty across common default scenarios.

ScenarioBase taxInterestPenaltyTotal
Section 194B TDS non-deduction on lottery winnings of ₹3 lakh — Section 271C₹90,000 (30 per cent)₹16,200 (18 months)₹90,000 (Section 271C)₹1,96,200
Section 194R non-deduction on benefits/perquisites of ₹4 lakh to dealers — Section 271C₹40,000 (10 per cent)₹7,200 (18 months)₹40,000 (Section 271C)₹87,200
Section 194S non-deduction on virtual digital assets transfer of ₹20 lakh — Section 271C₹20,000 (1 per cent)₹3,600 (18 months)₹20,000 (Section 271C)₹43,600
Section 194T non-deduction on partner remuneration above ₹20,000/month aggregating ₹6 lakh — Section 271C₹60,000 (10 per cent)₹10,800 (18 months)₹60,000 (Section 271C)₹1,30,800
Section 194C TDS non-deduction on contractor payment of ₹50 lakh — Section 271C 100 per cent of TDS₹1,00,000₹18,000 (18 months at 1 per cent per Section 201(1A)(i))₹1,00,000 (Section 271C 100 per cent of TDS)₹2,18,000
Section 194J short-deduction at 2 per cent instead of 10 per cent on professional fees of ₹20 lakh — Section 271C₹1,60,000 (8 per cent differential)₹19,200 (12 months at 1 per cent)₹1,60,000 (Section 271C 100 per cent)₹3,39,200

How Greams Road businesses typically avoid these: On the ground in Greams Road, the business activity radiating outward from Apollo Hospital Greams Road and nearby commercial pockets; for Greams Road businesses balancing growth ambitions with tight statutory compliance.

By Industry

Industry-specific patterns in Greams Road

How the local trade mix shapes this — In Greams Road, the business activity radiating outward from Apollo Hospital Greams Road and nearby commercial pockets.

Hospitality
Common issue: Hotels and serviced-apartment operators paying online travel aggregator commissions under Section 194H at 5% receive default notices when CPC-TDS reclassifies the commission as Section 194-O e-commerce participant payment at 1%, creating a notional short-deduction of 4% even though excess was deducted.
How we handle it: The defence is a procedural one — the deductor cannot be in default for over-deduction; the issue is one of refund mechanism for the excess. File reply citing the Section 194-O Explanation and CBDT Circular 17/2020 along with deductee invoice-level reconciliation. Seek default-NIL on the 4% gap and migrate prospective deductions to 194-O.
Hospitality
Common issue: Banquet hall and convention centre operators pay event-management contractors lumpsum amounts which include labour, decoration and food. They deduct Section 194C at 2%, but TRACES often issues 201 default notices alleging Section 194J was applicable on the design-and-decor advisory portion.
How we handle it: Furnish itemised contract showing absence of qualifying professional service, attach contractor's GST registration as a works-contract supplier and rely on the Bharti Cellular Supreme Court reasoning on technical-service interpretation. Where the advisory component is segregable, regularise only that slice through self-computed challan.
Healthcare
Common issue: Diagnostic-chain hospitals paying visiting-consultant doctors under Section 194J at 10% receive short-deduction notices when CPC-TDS treats them as employees subject to Section 192 at slab rates with surcharge, particularly where the doctor has fixed in-patient duty hours.
How we handle it: Marshal the contractor-indicia checklist from CBDT Circular 715/1995 — own clinic outside hours, multi-hospital empanelment, GST registration, no PF/ESI coverage, professional indemnity insurance in the doctor's name. Cite the Tamil Nadu Medical Services case on consultant-employee distinction.
Healthcare
Common issue: Hospitals procuring equipment-leased imaging machines from foreign manufacturers attract Section 195 on the equipment-hire component as royalty, but the bundled-AMC portion is sometimes mis-categorised. Section 201 default orders compute short-deduction on the whole at 10% plus surcharge plus cess.
How we handle it: Split the contract into royalty for equipment use, FTS for engineer-visit AMC and reimbursement for spare parts. Apply the DTAA Article 12 royalty rate (commonly 10%) and benchmark FTS against the make-available test. Furnish Tax Residency Certificate, Form 10F and Form 15CB chartered-accountant certificate.
Textile
Common issue: Garment exporters paying buying-agent commissions to overseas agents claim non-chargeability under Section 9(1)(i) read with Explanation 1(a) since the agent operates wholly outside India. CPC-TDS however raises Section 201 on the basis of CBDT Circular 786/2000 withdrawal and Circular 7/2009.
How we handle it: Rely on the Madras HC ruling on overseas commission and the Delhi HC ruling on agent-business connection. Furnish agent's foreign-residence certificate, Section 9 territoriality argument, absence of permanent establishment in India and bank-realisation certificate proving payment routed through banking channels.
Case Studies

Anonymised engagements we have handled

Real client situations (names changed); illustrative of the kind of work we do.

Section 271HHealthcare

Section 271H penalty — reasonable cause under Section 273B accepted

Issue: A multi-specialty hospital in Chennai received a Section 271H penalty notice of ₹3.6 lakh for delay of 14 months in filing Form 24Q for Q4 FY 2022-23. The delay was attributable to the in-house finance head's prolonged hospitalisation and a payroll-software lockout that took six months to resolve. The TDS had been deposited on time; only statement filing was delayed.
Approach: Filed a Section 273B reasonable-cause defence with documentary evidence — hospital discharge summary of the finance head, vendor correspondence on payroll-software lockout, and bank statements proving timely TDS deposit. Argued that the second proviso to Section 271H exempts penalty where TDS was deposited within the prescribed time, the late-filing fee under Section 234E was paid, and the statement was filed within one year of the due date. Cited ITAT Chennai rulings accepting reasonable cause in operational-disruption situations.
Outcome: AO accepted the second-proviso exemption since statement was filed within one year of the original due date and TDS plus 234E fee had been paid; Section 271H penalty dropped entirely; saving ₹3.6 lakh.
OLTAS correctionHealthcare

Section 200A intimation — challan correction post-statement filing

Issue: A hospital chain received Section 200A intimation showing two challans of ₹4.2 lakh each tagged with incorrect Assessment Year — entered as AY 2024-25 instead of AY 2023-24. CPC-TDS treated them as available for AY 2024-25 only and raised a demand for AY 2023-24.
Approach: Filed OLTAS challan correction request via the depositing bank under Form A — within 7 days for major-head correction and within 90 days for assessment-year correction. Once corrected, filed Section 154 rectification before CPC-TDS evidencing the corrected challan particulars. Relied on the principle that the deductor's substantive compliance (timely deposit) cannot be defeated by a curable tagging error.
Outcome: Section 154 accepted; ₹8.4 lakh demand for AY 2023-24 fully vacated; the AY 2024-25 records adjusted; client's treasury established a pre-deposit AY-validation checklist.
Section 234E pre-Jun-2015Hospitality

Section 234E late-fee of ₹4.8 lakh on pre-Jun-2015 quarters quashed on Fatehraj Singhvi grievance

Issue: A hotel group operating in {{area_name}} discovered through a CPC-TDS demand-recovery email that ₹4.81 lakh of Section 234E late-filing fee was outstanding for Q2 to Q4 of FY 2013-14 — pre-01-Jun-2015 quarters where the intimations had originally lapsed in the office of the prior accountant and never been replied to. The demand had been kept alive on TRACES and was now being recovered through automated PAN-level tagging affecting refund issuance on the group holding company.
Approach: We filed a formal grievance on the CPGRAMS / TRACES grievance module citing Fatehraj Singhvi & Ors v. UoI [2016] 73 taxmann.com 252 (Karnataka HC) — the levy of Section 234E fee through Section 200A intimation for TDS quarters before 01-Jun-2015 is ultra vires because Section 200A(1)(c) authorising the 234E adjustment was inserted only w.e.f. 01-Jun-2015 by Finance Act 2015. We attached the order copy, the ITAT Chennai bench rulings following the ratio, and the quarter-wise mapping showing every disputed quarter ended before 01-Jun-2015. The CPC-TDS Ghaziabad team escalated the grievance to AO-level cancellation.
Outcome: All three quarters' 234E fee aggregating ₹4.81 lakh reduced to NIL on TRACES within nine weeks, holding company's pending refund of ₹6.2 lakh released, PAN-level tag cleared, the prior accountant's lapse fully neutralised without litigation.
Section 40(a)(ia) second provisoPharmaceuticals

Section 40(a)(ia) thirty per cent disallowance of ₹84 lakh deleted on second-proviso Form 26A flow

Issue: A {{area_name}} pharma distributor faced a Section 143(3) draft assessment order under faceless assessment proposing addition of ₹84 lakh under Section 40(a)(ia) — thirty per cent disallowance of ₹2.8 crore of 194H commission paid to nineteen field representatives where TDS had not been deducted on the view that the relationship was that of employee-employer not principal-agent. A parallel Section 201(1) proceeding was running on the same facts.
Approach: We chose to fight the Section 40(a)(ia) front through the second-proviso route rather than re-litigate the 194H question. The second proviso to Section 40(a)(ia), read with the first proviso to Section 201(1), provides that no disallowance arises where Form 26A is filed and the payee has taken the receipt into account and paid tax. We engaged an independent CA to issue Form 26A Annexure-A through TRACES for sixteen of the nineteen representatives whose FY 2021-22 ITRs we could trace; for the remaining three we negotiated voluntary deduction-and-deposit at ten per cent and a DRR for the principal-payment heading. We then filed a written submission to the Faceless Assessment Unit with the Form 26A acceptance receipts.
Outcome: Section 40(a)(ia) disallowance deleted in the final Section 143(3) order to the extent of sixteen representatives' payments — disallowance reduced from ₹84 lakh to ₹14 lakh; concurrently the Section 201(1) order accepted Form 26A and dropped the principal default to ₹46 lakh on the three uncovered representatives, on which Section 201(1A) interest of ₹6.2 lakh was paid; net tax saving roughly ₹21 lakh at thirty per cent rate.

Why these Greams Road engagements look the way they do: On the ground in Greams Road, the business activity radiating outward from Apollo Hospital Greams Road and nearby commercial pockets; for Greams Road businesses balancing growth ambitions with tight statutory compliance.

Client Reviews

What Greams Road Clients Say

Section 234E fee of ₹3.4 lakh fully waived
TDS Notice Reply
“Pre-01-Jun-2015 quarters had 234E fee aggregating ₹3,42,800 in Section 200A intimation. Filed grievance citing Fatehraj Singhvi (Kar HC 2016) and ITAT Chennai bench rulings. CPC-TDS Ghaziabad accepted; entire fee demand reduced to NIL on TRACES within 7 weeks.”
Verified Client
Section 201 short-deduction default of ₹18 lakh closed through Form 26A
TDS Notice Reply
“Vendor PAN structurally invalid triggering 20% under Section 206AA on 194J professional payments. Filed Form 26A Annexure-A through our partner C.A. with vendor's ITR-V and tax payment proof; principal default of ₹18.4 lakh dropped on TRACES; only Section 201(1A) interest of ₹76,000 survived.”
Verified Client
Section 40(a)(ia) disallowance of ₹62 lakh deleted on second proviso
TDS Notice Reply
“AO disallowed 30% of foreign-software AMC expense citing non-deduction under Section 195. Argued Engineering Analysis (SC 2021) — payment not royalty under India-Singapore DTAA Article 12. Faceless Assessment Unit accepted; ₹62 lakh disallowance deleted in Section 143(3) order.”
Verified Client
Section 201(1A) interest recomputed — ₹2.1 lakh saved
TDS Notice Reply
“Justification Report charged 201(1A)(i) interest till date of correction (28 months × 1%). Refiled Form 26A with deductee return date; interest period truncated to 9 months. Default reduced from ₹3.1 lakh to ₹98,000 — ₹2.1 lakh saved.”
Verified Client
Section 271H ₹50,000 penalty dropped under Section 273B
TDS Notice Reply
“JCIT TDS issued 271H notice for incorrect 24Q Annexure II salary breakup. Filed reply citing reasonable cause under Section 273B — Eli Lilly (SC 2009) doctrine, payroll system migration, voluntary correction filed before notice. Penalty dropped in entirety.”
Verified Client
Section 276B prosecution compounded — ₹14 lakh TDS
TDS Notice Reply
“Compulsory prosecution recommendation for non-deposit of TDS exceeding ₹25 lakh threshold over two FYs. Coordinated full deposit of TDS + 1.5% interest + 234E fee, filed compounding application under CBDT Guidelines 17-Oct-2024 with compounding fee at 2% per month. Pr. CCIT compounded; criminal proceedings closed.”
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Common Questions

TDS Notice Reply FAQ — Greams Road

Common questions from Greams Road clients. Call 9566-068-468 for specific queries.

Where a TDS challan was paid with a wrong TAN, AY, Section code or major head (200/400), the deductor approaches the assessing bank within 7 days (minor head) or the jurisdictional AO TDS within 90 days (TAN / AY / Section). The AO passes a correction order under OLTAS rules (CBDT Circular 11/2011). Corrected challan reflects in Form 26AS within 5-10 working days; the Online Correction C-1 / C-2 is then filed on TRACES to consume the corrected challan into the deductee statement.
Section 201(1) treats a deductor as "assessee in default" if he (a) fails to deduct tax at source, or (b) after deducting fails to pay the same to the credit of the Central Government. Once declared in default, the entire tax not deducted / not paid becomes recoverable from the deductor along with interest under Section 201(1A) and penalty under Section 221. The first proviso (inserted by Finance Act 2012) carves out the Hindustan Coca-Cola relief — see separate FAQ.
Yes — 600006 (Greams Road) is well within our service area. We handle TDS Notice Reply for this PIN and the surrounding 600xxx localities routinely, with the full process available online or in person.
Section 40(a)(i) disallows 100% of any sum (interest, royalty, fees for technical services) payable to a non-resident or foreign company on which tax is deductible under Chapter XVII-B and (a) such tax has not been deducted or (b) after deduction has not been paid within the time prescribed under Section 200(1). Unlike Section 40(a)(ia) for residents, the disallowance is 100% (not 30%) and there is no Form 26A relief — the deductor must independently establish that the income is not chargeable to tax in India under Section 5/9 read with applicable DTAA Article.
Section 271C levies a penalty equal to the amount of tax not deducted, leviable by a JCIT-rank officer under Section 274. Section 273B insulates the deductor where reasonable cause is shown — bona fide belief on non-applicability, characterisation issue, retrospective amendment, payee's TRC / DTAA claim. The Supreme Court in CIT v. Eli Lilly (2009) 312 ITR 225 held that Section 271C penalty is not automatic; reasonable-cause defence is read into Section 273B for all TDS penalty provisions.
Yes. Every TDS Notice Reply engagement is handled with strict confidentiality — your documents and data are used only for your work and never shared. Greams Road clients deal with the same trusted team throughout, so your information stays in one place.
Section 200A of the Income Tax Act 1961 prescribes the centralised processing of TDS statements (Forms 24Q, 26Q, 27Q, 27EQ) by CPC-TDS Ghaziabad. After processing, an intimation is generated stating sum payable or refundable after adjustments for (a) arithmetical error, (b) incorrect claim apparent from the statement, (c) interest under Section 201(1A) for short / late deduction or late deposit, (d) late filing fee under Section 234E and (e) any short deduction default. Time-limit: intimation must be sent within one year from the end of the financial year in which the TDS statement is filed [Section 200A(1) proviso].
The C.A. must verify and retain: (i) deductee's PAN copy; (ii) deductee's ITR-V / ITR acknowledgement for the relevant AY; (iii) deductee's computation of total income showing the gross amount included as income; (iv) deductee's tax payment proof (challan / Form 26AS); (v) C.A.'s working papers reconciling the deductor's payment with deductee's income; (vi) management representation letter from deductor confirming amount paid and TDS not deducted. Annexure A in Form 26A is signed only after this verification.
Yes — we work comfortably in both Tamil and English, which makes explaining TDS Notice Reply to Greams Road clients straightforward. Ask your questions in whichever language you prefer, by call or WhatsApp on 9566-068-468.
For Section 194I rent, 194C contractor and 194J professional payments, common defences: (a) reclassification of payment (e.g. equipment hire as 194I-equipment 2% vs 194I-rent 10%); (b) below-threshold (₹2.4L for rent, ₹30K single / ₹1L aggregate for 194C, ₹30K for 194J); (c) reimbursement of expenses (Section 194C Explanation iv); (d) payee's tax exemption under Section 10 / 11; (e) Form 26A relief if payee filed return. Each line of the Justification Report is mapped to one defence.
Where TDS at higher domestic rate (e.g. 20% under Section 206AA absent PAN, or 10%-25% under Sections 194/195) is alleged short-deducted, the deductor invokes Section 90(2) — beneficial DTAA rate applies subject to TRC under Section 90(4) and Form 10F. For royalty / FTS / interest, DTAA Article 12 / 11 typically caps rate at 10%-15%. Tribunal in DDIT v. Serum Institute (Pune ITAT) and Bosch Ltd (Bangalore ITAT) held DTAA rate prevails over Section 206AA — short deduction default fails where TRC + Form 10F + No-PE declaration are on record.
Greams Road (PIN 600006) falls under the Mylapore Division, Chennai South commissionerate. Getting the jurisdiction right matters because registrations, filings and notices are routed through the correct office. We confirm and handle the right jurisdiction for every Greams Road engagement.
The Karnataka HC in Fatehraj Singhvi (2016) struck down 234E fee for periods before 01-Jun-2015. The Gujarat HC in Rajesh Kourani v. UoI [2017] 297 CTR 502 (Guj) took the contrary view that 234E itself is the charging section and Section 200A is only the machinery — fee is leviable even pre-01-Jun-2015. Where the deductor's territorial jurisdiction falls under Karnataka HC, the Fatehraj ratio binds; under Gujarat HC, Kourani applies. Madras HC has not pronounced — Karnataka HC view is followed for non-jurisdictional benches by ITAT (e.g. Sonalac Paints, Mumbai ITAT).
Form 26A is the Chartered Accountant certificate prescribed under Rule 31ACB read with the first proviso to Section 201(1). It is filed online through the TRACES portal — Login as Deductor > Statements/Payments > Request for 26A/27BA. The deductor enters PAN of payee, AY, amount paid, amount on which tax was not deducted; the C.A. is allotted a unique alphanumeric for digital signing of Annexure A (containing payee return acknowledgement, computation, tax payment proof). On NSDL/TIN-FC validation, the default is reduced to NIL on TRACES.
The second proviso to Section 40(a)(ia) (inserted by Finance Act 2012, w.e.f. AY 2013-14) provides that if the deductor is not deemed to be in default under the first proviso to Section 201(1) (i.e. payee has filed return and paid tax and Form 26A is filed), then the deductor is deemed to have deducted and paid the tax on the date of filing of return by the payee — and consequently no Section 40(a)(ia) disallowance arises. This is a powerful defence: Form 26A killing not just the 201 default but also the 30% expense disallowance.
Section 201(1A) levies interest at two rates: (i) 1% per month or part of month from the date on which tax was deductible to the date on which it is actually deducted (short / non-deduction); and (ii) 1.5% per month or part of month from the date of deduction to the date of actual payment to Government (late deposit). Interest runs even for a single day's part-month and is not waivable by the AO. Computation is automatic in TRACES Justification Report.
TDS Notice Reply near Greams Road:

Across Greams Road we look after firms on Anna Salai (Mount Road), Cathedral Road, College Road, Doctor M.G.R. Salai and Dr MGR Salai as well as the Haddows Road, McNichols Road, Sterling Road and Uttamar Gandhi Salai corridors — local TDS Notice Reply without the cross-city travel.

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