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Chennai West · Saidapet Division · Murugesan Salai TDS Notice Reply

TDS Notice Reply for Murugesan Salai (PIN 600087)

Qualified TDS Notice Reply for Murugesan Salai (PIN 600087) and adjacent Valasaravakkam — handled by a qualified, in-house team

TDS Notice Reply for commercial road through valasaravakkam businesses across the Murugesan Salai pocket near Arcot Road by qualified experts with a 15+ year, zero-penalty record. Call 9566-068-468.

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Quick Answer

How is interest under Section 201(1A) computed in Murugesan Salai, Chennai?

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.

Transparent Pricing

TDS Notice Reply in Murugesan Salai — 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 Murugesan Salai Clients Choose FilingPro

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

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.

15+ Years of TDS Practice in Chennai

Our team has handled TDS defaults since the TRACES portal launch in 2012-13 — over 200 Murugesan Salai deductors defended across Section 200A intimations, Section 201 orders, Section 234E fee challenges, Form 26A filings and Section 40(a)(ia) disallowance defences in scrutiny.

30-Day Section 220 Recovery Window Tracked

Every Section 200A intimation received by Murugesan Salai clients is logged with a 30-day countdown to Section 220(1) recovery. Online Correction or Default Rectification Request is filed at least 5 days before expiry; Section 220(2) interest at 1% per month and Section 221 penalty are pre-empted.

Key Benefits

What Murugesan Salai Clients Get

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

Section 234E Fee Wiped Out
Pre-01-Jun-2015 quarter Section 234E fees — often running into multi-lakh demands — are wiped out citing Fatehraj Singhvi (Kar HC 2016). The relief is unconditional once the period is established.
Section 201(1A) Interest Reduced 35-60%
Justification Report interest recomputed manually with Form 26A truncation, part-month audit and challan-date verification — typical reduction 35% to 60% of the originally raised 201(1A) demand.
Section 40(a)(ia) 30% Disallowance Defeated
Once Form 26A is on record, the 30% expense disallowance under Section 40(a)(ia) is defeated in the deductor's Section 143(3) assessment — saves 30% × business expenditure × applicable corporate / individual tax rate.
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.
Comparison

Section 200A Intimation vs Section 201 Default Order

Why this matters here — Murugesan Salai businesses operate where the business activity radiating outward from Murugesan Salai Bus Stop and nearby commercial pockets, and with quick access via Murugesan Salai Bus Stop and feeder routes connecting Murugesan Salai to the rest of Chennai.

AspectSection 200A IntimationSection 201 Default Order
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
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
Documents Required

Documents for TDS Notice Reply

Share documents via WhatsApp to 9566-068-468. No office visit required for Murugesan Salai 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 — Murugesan Salai businesses operate where the cluster of retail, restaurants, healthcare businesses that defines Murugesan Salai'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
Appeal to ITAT against CIT(A) order60 daysForm 36Right of second appeal under Section 253 lapses subject to delay condonation

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

Forms Library

Forms used in this engagement

Form 36Form of appeal to Income-tax Appellate Tribunal

Prescribed form for filing the second appeal before the ITAT against the order of the Commissioner (Appeals) under Section 250, with cross-objections under Section 253(4) where applicable.

Within sixty days of communication of the CIT(A) order Filed before the jurisdictional bench of the Income-tax Appellate Tribunal
Conso FileConsolidated TDS statement file from TRACES

Downloaded by the deductor from TRACES, used as the source dataset for preparing online or offline corrections to an earlier-filed quarterly statement.

Used as required for correction filings Downloaded from TRACES; corrected file uploaded to TIN-FC
Justification ReportDefault justification report from TRACES

Auto-generated PDF and CSV report listing default heads — short payment, short deduction, late deduction, late payment, interest and fee — against a processed quarterly statement.

Available within seven to ten days of intimation issue Generated by CPC-TDS Ghaziabad on TRACES
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

TDS Notice Reply in Murugesan Salai, Chennai 600087

Because PIN 600087 sits inside the Chennai West jurisdiction, the handling office for Murugesan Salai stays consistent across years, which matters when filings or approvals span cycles. Every Murugesan Salai engagement we open begins with the basics: PIN 600087, the Saidapet Division, and the coordinates 13.0419, 80.1731 that anchor the locality. Records we prepare for Murugesan Salai carry the geo-zone 600xx tag and coordinates 13.0419, 80.1731, which map each submission back to this locality. Statutory correspondence for Murugesan Salai businesses routes through the Saidapet Division, so we align every TDS Notice Reply engagement to that jurisdiction from the start.

Most commerce in Murugesan Salai — invoices, expenses, purchases and statutory records — eventually surfaces in the TDS Notice Reply working file we maintain for clients here. The businesses clustered around Arcot Road in Murugesan Salai drive the bulk of the TDS Notice Reply workload we see each cycle. Freight and foot traffic from the Murugesan Salai Bus Stop hub pull steady daily commerce through Murugesan Salai, so there is rarely a quiet filing month in this commercial road through valasaravakkam pocket. Murugesan Salai sustains a high flow of commerce for a commercial road through valasaravakkam locality, and that flow is the raw material for the TDS Notice Reply files we close here.

The business mix in Murugesan Salai centres on coaching, and that sector carries its own TDS Notice Reply quirks we plan for in advance. For a coaching business in Murugesan Salai, the TDS Notice Reply scope is rarely generic; we tailor the checklist to how that sector actually transacts. Mixed coaching activity across Murugesan Salai means our TDS Notice Reply team keeps sector playbooks ready rather than improvising per client. The coaching firms we serve in Murugesan Salai value a TDS Notice Reply partner who already understands their sector's compliance rhythm.

A Murugesan Salai client sees the same TDS Notice Reply cadence each cycle: intake, reconciliation, review, filing, acknowledgement. Working papers for Murugesan Salai TDS Notice Reply engagements stay archived and retrievable, which makes any later notice or query straightforward to answer. Our Murugesan Salai TDS Notice Reply process is built to be predictable, documented, and on time, cycle after cycle. From the first TDS Notice Reply cycle, a Murugesan Salai engagement is set up to be audit-ready rather than reconstructed under pressure later.

Proximity to Ags Colony Valasaravakkam means a Murugesan Salai engagement can extend across the locality cluster with no change in cadence. Group companies spread across Murugesan Salai and Ags Colony Valasaravakkam consolidate their TDS Notice Reply under one engagement with us. From the same Murugesan Salai team we also serve Ags Colony Valasaravakkam and other nearby localities without re-onboarding clients. TDS Notice Reply clients in Ags Colony Valasaravakkam are handled by the same practitioners who run our Murugesan Salai desk.

Each engagement in Murugesan Salai adds to a record of what the Chennai West jurisdiction expects, sharpening the next TDS Notice Reply file. Recurring gaps in Murugesan Salai restaurants records are the first thing our TDS Notice Reply review closes out. Patterns we track for Murugesan Salai include restaurants documentation gaps, timing mismatches, and the questions the Saidapet Division tends to raise. The longer we serve Murugesan Salai, the more precisely we predict where a TDS Notice Reply file needs attention.

A startup setting up near Murugesan Salai Bus Stop in Murugesan Salai gets a TDS Notice Reply foundation built for the Saidapet Division from day one. When a Valasaravakkam business expands into Murugesan Salai, we extend its TDS Notice Reply setup to PIN 600087 without disruption. Incorporating in Murugesan Salai comes with jurisdiction, registration and TDS Notice Reply steps that we sequence so nothing stalls the launch. First-time TDS Notice Reply for a Murugesan Salai business is where getting the basics right saves years of cleanup later.

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Expert Guide

TDS Notice Reply in Murugesan Salai — Complete Guide

TDS Notice Reply for Murugesan Salai (600087) 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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Key Facts — TDS Notice Reply in Murugesan Salai
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 Murugesan Salai
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 the interest rate under Section 201(1A)?

Section 201(1A)(i) levies interest at 1 per cent per month from the date of credit/payment to the date of deduction for non-deduction; Section 201(1A)(ii) levies 1.5 per cent per month from the date of deduction to the date of deposit for non-payment after deduction.

Is Section 271C penalty automatic on Section 201 default?

No. Section 271C requires separate proceedings with show-cause. Section 273B provides a complete reasonable-cause defence — bona fide reliance on opinion, vendor's Form 26A, or genuine difference of interpretation negates penalty. The Madras HC has consistently treated Section 271C as not strict-liability.

What is prosecution exposure under Section 276B?

Section 276B prescribes rigorous imprisonment of 3 months to 7 years plus fine for failure to deposit TDS already deducted. Personal directors may be prosecuted. Compounding under Section 279(2) per CBDT Guidelines dated 17 Oct 2024 is the standard mitigation at 3 per cent of TDS.

Can I compound a Section 276B prosecution case?

Yes. Compounding under Section 279(2) read with CBDT Guidelines dated 17 Oct 2024 is available. Compounding fee is 3 per cent of TDS for first offence, 5 per cent for subsequent. Pay full principal TDS, Section 201(1A) interest, Section 234E fee, then apply.

What is the Madras HC view on Section 201 limitation?

The Madras HC has consistently held that Section 201(3) is a jurisdictional limit; orders beyond the seven-year window (six years pre-Finance (No. 2) Act 2024) are without authority of law. Limitation defence is preserved even where merits are weak.

How do I claim DTAA relief on a Section 195 remittance?

Obtain Tax Residency Certificate (TRC) from the non-resident's home country, obtain Form 10F (now electronically generated mandatorily), file Form 15CA-15CB chartered accountant certificate, apply the DTAA rate per Section 90(2) where more beneficial than domestic law.

What Murugesan Salai clients want to know before signing: On the ground in Murugesan Salai, in the commercial road through valasaravakkam micro-market of Murugesan Salai.

Expert Guide

A complete walkthrough — Tds Notice Reply

Reading this guide locally — Murugesan Salai businesses operate where in the commercial road through valasaravakkam micro-market of Murugesan Salai.

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.

Section 201 default order — deemed-default mechanics

Form 26A Annexure A and the practitioner-CA route

Form 26A is the operational vehicle for the first proviso to Section 201(1). It requires a chartered accountant in practice to certify that the deductee has — first, included the relevant payment in computing taxable income in the return filed under Section 139, second, paid the tax on the income, and third, furnished the deductor a declaration to this effect. The Form is filed by the deductor through the TRACES portal with the chartered accountant signing Annexure A on Digital Signature Certificate. On acceptance, the Section 201(1) principal-default head is reduced to NIL but the Section 201(1A) interest survives. The Mumbai ITAT in JDS Apparels held that Form 26A is a complete remedy on the principal head.

Reasonable cause defence under Section 273B

Section 273B provides a reasonable-cause umbrella defence applicable to Section 271H and certain other penalty provisions. The Supreme Court in Hindustan Steel v State of Orissa established that penalty cannot be imposed for technical or venial breach where the assessee acted bona fide. Karnataka HC in CIT v Mascon Multi-Services and Madras HC in CIT v Universal Trade Links applied the doctrine to TDS-deduction-shortfall scenarios where the deductor relied on a beneficial interpretation supported by an Authority for Advance Rulings determination or a tribunal precedent. The defence is fact-intensive — bona fides must be demonstrated through contemporaneous documentation rather than reconstruction.

Short-deduction versus non-deduction taxonomy

Section 201 distinguishes — though not always explicitly — between non-deduction (no TDS deducted at all), short-deduction (TDS deducted at a rate or amount lower than what was required), late-deduction (TDS deducted after the prescribed time), and non-deposit (TDS deducted but not deposited with the exchequer). The interest-rate under Section 201(1A) is 1% per month for non-deduction and short-deduction, and 1.5% per month for the deduction-not-deposited category. The disallowance under Section 40(a)(ia) attaches only to non-deduction and non-deposit categories — short-deduction by rate does not invite disallowance per the Calcutta High Court ruling in S.K. Tekriwal, since-followed by multiple benches.

Section 234E late-filing fee — challenge points

Statutory architecture

Section 234E was inserted by Finance Act 2012 with effect from 01-Jul-2012 levying a fee of ₹200 per day of delay in filing the quarterly TDS statement, capped at the amount of tax deductible. Sub-section (4) of Section 234E declares the fee non-leviable in the cases prescribed — but no such prescription has been issued by CBDT to date. The fee is a fee in the technical sense (a charge for services rendered by the department's processing-system) rather than a penalty, as held by the Karnataka HC in Lakshminirman Bangalore. This technical classification is significant — fee does not require mens rea, is not appealable under Section 246A on merits, and is not subject to Section 273B reasonable-cause relief.

Pre-01-Jun-2015 quarter challenge

The Karnataka HC in Fatehraj Singhvi v Union of India held that prior to the insertion of clause (c) in Section 200A(1) by Finance Act 2015 effective 01-Jun-2015, there was no enabling mechanism for CPC-TDS to levy Section 234E fee through a Section 200A intimation. The clause-(c) insertion was prospective only — fees raised on quarterly statements pertaining to periods before 01-Jun-2015 are therefore liable to be set aside. The Allahabad HC in Sushila Devi Pyala followed Fatehraj Singhvi. The Gujarat HC in Rajesh Kourani took a contrary view holding that Section 234E itself was the charging provision and 200A(1)(c) was merely procedural. The Madras HC has not authoritatively pronounced.

Cap on fee and computational disputes

Sub-section (3) of Section 234E provides that the fee shall not exceed the amount of tax deductible or collectible. The cap operates at the statement-level, not at the deductee-level — Mumbai ITAT in Sonal Vyas v ITO held that where the quarterly TDS deductible is ₹1.2 lakh and the delay-days × ₹200 computes to ₹1.8 lakh, the fee is capped at ₹1.2 lakh. Computational disputes commonly arise on the day-count — whether the delay is counted from the original due-date or from any extended date notified by CBDT under press-release. The conservative position is to count from the original due-date and seek reduction citing the extension order on merits.

Section 271H penalty for non-filing or false particulars

Distinction from Section 271C and Section 276B

Section 271H is distinct from two adjacent penalty / prosecution provisions. Section 271C imposes a penalty equal to the amount of tax that ought to have been deducted on failure to deduct — operating on non-deduction itself, whereas 271H operates on non-filing-of-statement or false-particulars. Section 276B is the prosecution provision for failure to pay TDS deducted to the credit of Central Government, attracting rigorous imprisonment of three months to seven years. Section 278AA provides a defence to 276B where reasonable cause is shown. The Madras HC in Madhumilan Syntex Ltd applied a strict reading on 276B prosecution where deduction-and-non-deposit was established.

Penalty range and triggers

Sub-section (1) of Section 271H provides for a penalty of not less than ₹10,000 and not more than ₹1,00,000 where a person fails to deliver the quarterly statement within the prescribed time or where the statement furnished contains false particulars in respect of tax deduction, payment, deductee details or any matter relevant to determination of total income of the deductee. The penalty is imposable by the Assessing Officer (TDS) after recording satisfaction and issuing a show-cause notice. The provision is wider than Section 234E in two respects — it covers false-particulars (not merely delay) and the upper-cap is materially higher.

Safe-harbour under sub-section (3)

Sub-section (3) of Section 271H provides a safe-harbour — penalty shall not be levied where the deductor proves that — clause (a) the tax deducted along with interest has been paid to the credit of Central Government, and clause (b) the statement has been delivered before the expiry of one year from the time prescribed for delivery. The safe-harbour operates on a cumulative basis — both conditions must be satisfied. The Mumbai ITAT in Saroj Singh ruled that even one-day delay beyond the one-year limit takes the deductor outside the safe-harbour and the penalty becomes leviable, subject only to Section 273B reasonable-cause defence.

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

Glossary

Plain-English glossary for this service

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.

Section 197A Self-Declaration

Section 197A Self-Declaration is the self-declaration in Form 15G or Form 15H by which a deductee whose estimated total income is below the basic exemption limit certifies to the deductor that no tax need be deducted. The declarations are filed by the deductor on the e-filing portal with quarterly periodicity under Rule 29C.

TDS Rate in Force

TDS Rate in Force is the rate at which tax is to be deducted under each section of Chapter XVII-B, as prescribed by the relevant section read with the Finance Act or the rates in the Finance Act schedule, including any surcharge and health and education cess applicable to the deductee category. Rate determination is the first analytical step in any default defence.

Pre-deposit Norm

Pre-deposit Norm is the administrative requirement under the Central Board of Direct Taxes Instruction 1914 dated the second day of December 1993, as modified by the Office Memorandum dated the thirty-first day of July 2017, that ordinarily twenty per cent of the disputed demand be deposited as a condition for stay under Section 220(6) pending first appeal.

Quarter of Deduction

Quarter of Deduction is the calendar quarter — April-June, July-September, October-December or January-March — to which a deduction relates, determined by the earlier of the date of credit or the date of payment under Section 200(1). Misallocation of a deduction across quarters is a common driver of short-payment defaults in the Justification Report.

Justification Report

Justification Report is the line-by-line default register downloadable from TRACES (Defaults > Justification Report Download) showing every short-payment, short-deduction, late-payment and 234E entry against the deductor's filed statement. It comes in PDF summary and CSV deductee-wise form, both required for a complete Section 200A reply.

Conso File

Conso File is the consolidated TDS statement file generated by TRACES that combines the original and all correction statements filed for a particular Form Type, Financial Year and Quarter. It is the input file for any further Online Correction and must be downloaded from Statements > Request for Conso File before any C-1 to C-9 correction is initiated.

Online Correction Category C-3

Online Correction Category C-3 on TRACES is the PAN Correction category used to amend deductee PAN entries in a filed TDS statement without re-uploading the entire return. It is the workhorse correction for Section 206AA short-deduction defaults caused by structurally invalid PAN or inoperative PAN-Aadhaar status.

Default Rectification Request

Default Rectification Request or DRR is raised on TRACES against an erroneous default flagged by CPC-TDS where the underlying statement is already correct — typically challan-paid-but-not-visible due to BIN mismatch, OLTAS sync delay, or system computation errors. Unlike Online Correction, no fresh statement is filed; only the default tag is rectified.

Form 26A Annexure-A

Form 26A Annexure-A is the Chartered Accountant certificate filed online through TRACES under Rule 31ACB read with the first proviso to Section 201(1) certifying that the resident payee has filed his Section 139 return, taken the receipt into account and paid the tax. It wipes out principal short-deduction default but Section 201(1A)(i) interest survives.

Cost of Non-Compliance

Real-world penalty exposure

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

ScenarioBase taxInterestPenaltyTotal
Section 194Q non-deduction on goods purchase of ₹2 crore — Section 271C₹20,000 (0.1 per cent)₹3,600 (18 months)₹20,000 (Section 271C)₹43,600
Section 194H non-deduction on commission of ₹8 lakh — Section 271C₹40,000 (5 per cent)₹7,200 (18 months)₹40,000 (Section 271C)₹87,200
Section 194D non-deduction on insurance commission ₹6 lakh — Section 271C₹30,000 (5 per cent)₹5,400 (18 months)₹30,000 (Section 271C)₹65,400
Section 194A non-deduction on interest of ₹4 lakh paid to non-banking party — Section 271C₹40,000 (10 per cent)₹7,200₹40,000 (Section 271C)₹87,200
TDS deducted but not deposited — ₹6 lakh held for 90 days — Section 276B prosecution exposure₹6,00,000 (TDS)₹27,000 (3 months at 1.5 per cent under Section 201(1A)(ii))Prosecution under Section 276B (3 months to 7 years rigorous imprisonment + fine)₹6,27,000 + prosecution risk
Section 194N non-deduction on cash withdrawal of ₹1.5 crore by non-co-operative entity — Section 271C₹2,00,000 (2 per cent on excess over ₹1 crore)₹36,000 (18 months)₹2,00,000 (Section 271C)₹4,36,000

How Murugesan Salai businesses typically avoid these: On the ground in Murugesan Salai, the business activity radiating outward from Murugesan Salai Bus Stop and nearby commercial pockets; for Murugesan Salai businesses balancing growth ambitions with tight statutory compliance.

By Industry

Industry-specific patterns in Murugesan Salai

How the local trade mix shapes this — Murugesan Salai businesses operate where the business activity radiating outward from Murugesan Salai Bus Stop and nearby commercial pockets.

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.
Retail
Common issue: Multi-store retail chains running franchise-fee outflows under Section 194J at 10% receive default notices when CPC-TDS reclassifies the trade-name licence as royalty under Section 9(1)(vi), attracting different TDS rate and DTAA implications where the franchisor is foreign.
How we handle it: Argue that domestic franchisor royalties are caught by Section 194J Explanation (b) on royalty within India and that 10% is the right rate. For cross-border franchisors invoke the relevant DTAA Article 12 royalty cap with TRC, Form 10F and beneficial-ownership declaration. Cite Sheraton International Inc Delhi HC.
Retail
Common issue: Retail chains running cashback and loyalty point pay-outs to customers fail to consider Section 194R (1% TDS on benefits exceeding ₹20,000) where the cashback is denominated in points convertible to merchandise rather than cash, drawing Section 201 demands post 01-Jul-2022.
How we handle it: Map each loyalty-programme tier to CBDT Circular 12/2022 and 18/2022 Section 194R guidance, distinguish customer-promotion (excluded) from business-relationship benefit (included). Where the customer is a business with B2B relationship the 194R obligation crystallises; pay self-computed challan with Section 201(1A) interest and absorb principal.
Restaurants
Common issue: Restaurant chains paying rent above ₹2.4 lakh per annum on commercial premises deduct Section 194-I at 10% on plant-and-machinery rent and 10% on land-and-building rent. Composite-rent agreements covering both heads often draw Section 201 short-deduction when CPC-TDS reclassifies portions.
How we handle it: Split the lease agreement into building-rent (10%) and equipment-rent (2%), produce schedule of demised equipment with reference to landlord's depreciation register. Cite the CBDT Circular 1/2018 on composite-rent and the Delhi ITAT ruling on Section 194-I sub-heads.
Case Studies

Anonymised engagements we have handled

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

Section 206AA 20 per centRetail

Section 200A — Section 234E for non-PAN deductee declaration

Issue: A retailer received a Section 200A intimation showing short-deduction of ₹2.4 lakh because TDS had been deducted at 1 per cent under Section 194C for six contractors who had not furnished PAN, where Section 206AA mandated 20 per cent in absence of PAN.
Approach: Reviewed the contractor records — three of the six had furnished PAN belatedly after the deduction date. For those, filed correction statement with the now-available PAN and re-flagged the deduction at the correct rate (with retrospective effect being unavailable, claimed Form 26A relief from those deductees). For the remaining three, accepted the Section 206AA position and paid the short-deduction with Section 201(1A) interest.
Outcome: Short-deduction reduced from ₹2.4 lakh to ₹84,000 (relating to the three deductees who never furnished PAN); Form 26A relief secured for the three subsequently-PAN-furnished deductees; client SOP — PAN-on-file is now a pre-payment gate.
Section 234E reasonable causeRetail

Section 234E late-fee resolution where deductor missed the eight-day buffer — partial relief on reasonable cause

Issue: A multi-outlet retail chain in {{area_name}} filed Q1 FY 2023-24 Form 24Q sixty-two days late after the centralised payroll system migration to a new vendor failed mid-quarter. Section 234E fee at ₹200 per day worked out to ₹12,400 per statement across four 24Q statements — total ₹49,600 plus Section 271H penalty notice issued by the JCIT TDS for ₹35,000. Both demands hit in the same week and the post-Jun-2015 timing meant the Fatehraj Singhvi ground was not available.
Approach: We segregated the two heads — Section 234E fee was conceded as statutorily levied under Section 200A(1)(c) post Jun-2015 with no discretion vested in the AO, but we challenged the Section 271H penalty under Section 271H(3) immunity (TDS + interest + fee paid before the proposed penalty order) read with Section 273B reasonable cause. We documented the payroll-vendor migration with email trails, system-error screenshots, board minutes authorising the change, and the voluntary filing of the statement immediately on system restoration. The Eli Lilly (SC 2009) doctrine was cited for reasonable-cause TDS defaults.
Outcome: Section 234E fee of ₹49,600 paid in full as legally mandated, Section 271H penalty of ₹35,000 dropped under Section 271H(3) read with Section 273B in the order dated within sixty days, total saving ₹35,000 against gross exposure of ₹84,600; lessons-learned memo to client recommended an internal eight-day filing buffer ahead of due dates.
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.
TRACES OLTAS mismatchRetail

Section 200A intimation — TRACES challan mismatch reconciled

Issue: A retail electronics chain received a Section 200A intimation for Q2 FY 2023-24 reflecting an unmatched challan of ₹2,84,000 — the OLTAS challan was tagged under the wrong TAN by the bank. CPC-TDS treated the amount as unpaid and raised a demand including Section 201(1A) interest of ₹47,300.
Approach: Obtained the OLTAS challan correction by writing to the depositing branch with Form A correction request. Once the OLTAS database was corrected and the challan re-tagged to the correct TAN, filed a correction statement under Rule 31A re-flagging the challan. Filed Section 154 rectification before CPC-TDS with the corrected challan-tagging evidence. Cited the principle that the deductor cannot be penalised for a banking misallocation where deposit timing is proven.
Outcome: Section 154 rectification accepted; demand of ₹2,84,000 along with Section 201(1A) interest fully reversed; refund-adjustment processed against subsequent quarter; total relief ₹3.31 lakh.

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

Client Reviews

What Murugesan Salai 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.”
Verified Client
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Common Questions

TDS Notice Reply FAQ — Murugesan Salai

Common questions from Murugesan Salai clients. Call 9566-068-468 for specific queries.

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.
Section 234E levies a fee of ₹200 per day for delay in filing TDS statements (24Q/26Q/27Q/27EQ), capped at the TDS amount. The Karnataka High Court in Fatehraj Singhvi & Ors v. Union of India [2016] 73 taxmann.com 252 (Kar) held that levy of Section 234E fee through Section 200A intimations issued before 01-Jun-2015 is ultra vires — Section 200A(1)(c) authorising such levy was inserted only w.e.f. 01-Jun-2015 by Finance Act 2015. Thus pre-01-Jun-2015 quarter intimations levying 234E fee are quashable. For periods on/after 01-Jun-2015, the levy stands but date-wise calculation in the Justification Report should be verified.
Absolutely. Most Murugesan Salai clients complete the entire TDS Notice Reply process remotely — we collect documents on WhatsApp or email, share drafts for your approval, and file on your behalf. A visit to our Maduravoyal office is optional, never required.
Section 201(3) (as substituted by Finance (No. 2) Act 2014) prescribes a 7-year limit from the end of the FY in which payment is made / credit is given for passing an order treating the deductor as in default in respect of resident payees. For non-resident payees there is no statutory time-limit, however, courts have read in a reasonable period (typically 4-6 years) — see Vodafone Idea / Mahindra Holidays line of cases. Time-barred 201 orders are quashable on writ.
DRR is the online module on TRACES (Defaults > Request for Resolution) for raising a ticket against an erroneous default — e.g. challan paid but not tagged, BIN mismatch for govt deductors, double-counted interest. The deductor submits the request with reference to the Justification Report; CPC-TDS Ghaziabad responds within 30-45 days. DRR is the appropriate remedy where Online Correction is not possible (e.g. challan deposited but not visible in OLTAS).
Yes. Every TDS Notice Reply engagement comes with a GST invoice and copies of all filings, acknowledgements and challans for your records. Murugesan Salai clients receive a clean, documented trail they can rely on later.
Compounding is governed by CBDT Guidelines for Compounding of Offences dated 17-Oct-2024 (latest revision). Application is filed in the prescribed compounding form to the jurisdictional Pr. CCIT with: (a) full payment of TDS + interest under Section 201(1A) + 234E fee; (b) compounding fee at 1.5% to 3% of the TDS amount per month of delay; (c) declaration of no other prosecution. Compounding closes the prosecution; non-compounding leads to trial in Magistrate Court.
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].
On completion we hand over every relevant document — certificates, acknowledgements, challans and a short summary of what was done — so your TDS Notice Reply record is complete. Murugesan Salai clients keep a clean file they can produce anytime.
Section 276B prescribes rigorous imprisonment from 3 months to 7 years and fine where a person fails to pay to the credit of Central Government the tax deducted at source. CBDT Instruction F. No. 285/90/2013-IT(Inv.V) dated 24-Apr-2008 (modified time to time) sets a non-deposit threshold of ₹25 lakh for compulsory prosecution; below ₹25 lakh, the Pr. CCIT / CCIT may compound under Section 279(2). Recent prosecutions have surged since FY 2019-20 — defence is to deposit the TDS + 1.5% interest before the show-cause and apply for compounding.
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. The first discussion about your TDS Notice Reply requirement is free — call or WhatsApp 9566-068-468 and we will tell you honestly what is involved, what it costs, and the realistic timeline before you commit to anything.
Step 1: Deductor logs into TRACES > Statements > Request for 26A/27BA > Add Default Rows. Step 2: Add deductee PAN, FY, amount paid, amount on which tax not deducted. Step 3: System generates an alphanumeric token + assigns rows to a C.A. nominated by the deductor. Step 4: C.A. logs into TRACES C.A. login, downloads Annexure A in Form 26A, verifies payee return / tax payment, signs digitally with DSC. Step 5: System forwards to deductor for final submission. Step 6: On NSDL acceptance, default heads under 201(1) drop to NIL; only 201(1A) interest survives.
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.
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.
Engineering Analysis Centre of Excellence v. CIT [2021] 432 ITR 471 (SC) held that payments by Indian resident end-users / distributors to non-resident computer software manufacturers / suppliers for resale or use of computer software through EULAs / distribution agreements is NOT royalty under Article 12 of applicable DTAAs (read with Section 90(2)) and hence no obligation to deduct TDS under Section 195. This judgment closed thousands of pending Section 201 / 40(a)(i) demands on software royalty TDS.

Our TDS Notice Reply clients in Murugesan Salai are spread right across the locality — along Radhakrishna Salai, Arcot Road, Alapakkam Main Road, Sri Devi Kuppam Main Road and 1st Cross Main Road, and through the 1st Main Road, 1st main road, 2nd Main Road and 3rd Main Road business stretches — so wherever your premises sit, expert help is close by.

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Professional TDS Notice Reply in Murugesan Salai, Chennai. Call @ 9566-068-468. Offices at Maduravoyal, Nerkundram & Nolambur (upcoming). 15+ years experience, 4.9★ rated.

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Maduravoyal · Nerkundram · Nolambur (upcoming)
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