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
Pattabiram & Avadi · TDS Notice Reply practitioners

TDS Notice Reply near Pattabiram Railway Station, Pattabiram

the business activity radiating outward from Pattabiram Railway Station and nearby commercial pockets — handled by a qualified, in-house team

TDS Notice Reply for defence and residential mixed businesses across the Pattabiram pocket near Avadi Cantonment — qualified review, a 7-year workpaper archive and fixed fees from day one. Call 9566-068-468.

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312+ Reviews
15+ Years
Zero Penalties
500+ Clients
Quick Answer

What is the Hindustan Coca-Cola / first proviso to Section 201(1) relief in Pattabiram, Chennai?

The first proviso to Section 201(1) (inserted by Finance Act 2012, w.e.f. 01-Jul-2012) — codifying CIT v. Hindustan Coca-Cola Beverages Pvt Ltd [2007] 293 ITR 226 (SC) — provides that the deductor shall NOT be deemed to be in default if the resident payee (i) has furnished his return of income under Section 139, (ii) has taken into account such sum for computing income in such return, (iii) has paid the tax due on the income declared, and (iv) the deductor furnishes a certificate to this effect from a Chartered Accountant in Form 26A (Annexure A). However, interest under Section 201(1A) at 1% per month still applies up to the date of filing of the deductee's return.

Transparent Pricing

TDS Notice Reply in Pattabiram — 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 Pattabiram Clients Choose FilingPro

Expert TDS Notice Reply in Pattabiram — 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 Pattabiram 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 Pattabiram 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 Pattabiram Clients Get

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

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.
Refund of Over-paid TDS Recovered
Where TDS was over-paid against subsequently-extinguished default (e.g. Form 26A filed retroactively), refund is claimed in Form 26B on TRACES under Rule 31A(4A) — refund credited to deductor's bank account.
Section 195 Software TDS Defeated
Section 195 short-deduction on software / cloud / SaaS payments to non-residents defeated citing Engineering Analysis (SC 2021) — payment not royalty under DTAA Article 12, no Section 201 default, no Section 40(a)(i) disallowance, no Section 271C penalty.
Comparison

Section 200A Intimation vs Section 201 Default Order

Why this matters here — In Pattabiram, the cluster of defence, residential, logistics businesses that defines Pattabiram's commercial fabric; served by short connections to Avadi and Tirumullaivoyal and onward to central Chennai.

AspectSection 200A IntimationSection 201 Default Order
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
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
Documents Required

Documents for TDS Notice Reply

Share documents via WhatsApp to 9566-068-468. No office visit required for Pattabiram 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 Pattabiram, Pattabiram businesses in the defence arm find that businesses serve a captive customer base under Section 51 GST TDS DGS&D rate contracts and quarterly 26Q filings; the business activity radiating outward from Pattabiram Railway Station and nearby commercial pockets.

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
Service of Section 156 notice of demand pursuant to Section 201 order30 daysPayment challan or Section 220(6) stay applicationRecovery proceedings under Sections 222 to 226 stand triggered

Deadline pressure points we see in Pattabiram: Closer to Pattabiram, supporting the defence-establishment civilian workforce that lives in the surrounding cantonment-friendly housing, which is why for the professional and salaried population of Pattabiram navigating personal-tax and home-office GST.

Forms Library

Forms used in this engagement

Forms most asked about here — In Pattabiram, with most filings in this catchment being personal income-tax returns under ITR-1 to ITR-3 and one-off TDS reconciliations; supporting the defence-establishment civilian workforce that lives in the surrounding cantonment-friendly housing.

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 Pattabiram, Chennai 600072

Because PIN 600072 sits inside the Chennai West jurisdiction, the handling office for Pattabiram stays consistent across years, which matters when filings or approvals span cycles. Businesses registered in Pattabiram share the Chennai West jurisdiction, and their statutory matters route through the same Avadi Division each time. For TDS Notice Reply at PIN 600072, understanding the Avadi Division's documentation norms removes most of the friction from the process. The 600xx geo-zone covering Pattabiram groups several locality clusters under common administration, keeping documentation expectations predictable.

Pattabiram reads as a defence and residential mixed pocket with medium commercial activity, anchored around Pattabiram Railway Station and fed by the Pattabiram Railway Station corridor. Vendors and customers tied to the Pattabiram Railway Station network show up across the invoice trail we reconcile for Pattabiram TDS Notice Reply clients. Document pickup near Pattabiram Railway Station is a same-hour errand for our Pattabiram engagements rather than the half-day a typical Chennai client expects. Working in Pattabiram brings a logistical edge: proximity to Pattabiram Railway Station and the Pattabiram Railway Station corridor keeps physical document handling fast.

TDS Notice Reply for residential businesses in Pattabiram hinges on getting the sector's recurring entries right the first time. We have closed enough TDS Notice Reply files for residential firms near Pattabiram to know where the department usually probes. residential units around Pattabiram share recurring TDS Notice Reply patterns — input-credit timing, vendor reconciliation, and sector-specific documentation. Mixed residential activity across Pattabiram means our TDS Notice Reply team keeps sector playbooks ready rather than improvising per client.

We keep a repeatable TDS Notice Reply checklist for Pattabiram so nothing in the cycle is improvised or missed. Our Pattabiram TDS Notice Reply process is built to be predictable, documented, and on time, cycle after cycle. The Pattabiram TDS Notice Reply workflow is documented end-to-end: WhatsApp document intake, a working file, qualified review, and a filed acknowledgement back to you. The qualified-review step on every Pattabiram TDS Notice Reply file is where errors get caught before they reach the portal.

Group companies spread across Pattabiram and Korattur consolidate their TDS Notice Reply under one engagement with us. A client relocating between Pattabiram and Korattur keeps the same TDS Notice Reply file and the same team. Serving Pattabiram and Korattur from one team keeps TDS Notice Reply turnaround identical across the cluster. Proximity to Korattur means a Pattabiram engagement can extend across the locality cluster with no change in cadence.

Over several cycles in Pattabiram, the recurring TDS Notice Reply issues cluster around a predictable short list we screen for early. Because we work repeatedly across Pattabiram, we can benchmark a new client's TDS Notice Reply position against the locality norm. Each engagement in Pattabiram adds to a record of what the Chennai West jurisdiction expects, sharpening the next TDS Notice Reply file. Common patterns in the Avadi Division give Pattabiram businesses an early-warning map we use to pre-empt TDS Notice Reply issues.

A startup setting up near Avadi Cantonment in Pattabiram gets a TDS Notice Reply foundation built for the Avadi Division from day one. New residential ventures in Pattabiram lean on us to stand up TDS Notice Reply correctly before the first deadline rather than after a notice. Relocating a registered office into Pattabiram (PIN 600072) changes the assessing division, and we handle that TDS Notice Reply transition cleanly. First-time TDS Notice Reply for a Pattabiram business is where getting the basics right saves years of cleanup later.

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Expert Guide

TDS Notice Reply in Pattabiram — Complete Guide

For Pattabiram (600072) deductors, FilingPro covers the complete TDS lifecycle — Section 200A processing intimation, Section 201(1) order treating the deductor as "assessee in default", Section 201(1A) interest computation, Section 271C / 271H penalty, Section 276B prosecution compounding, Section 40(a)(ia) 30% expense disallowance defence in Section 143(3) assessment, and CIT(A) Section 250 / ITAT Section 253 appeals where adjudication is adverse. Each case is led by a Chartered Accountant with 15+ years of TDS practice.

Get Expert Help Today
Qualified professionals handle your TDS Notice Reply in Pattabiram. 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 Pattabiram
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 Pattabiram
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 role of TRACES in TDS notice management?

TRACES is the deductor-side portal for filing statements, viewing defaults, downloading consolidated files for corrections, generating Form 16/16A, registering grievances, and tracking refunds. CPC-TDS at Vaishali, Ghaziabad operates the back-end processing per the Centralised Processing of Statements Scheme 2013.

How do I challenge a Section 271C penalty in Chennai?

File a reply to the show-cause invoking Section 273B reasonable-cause defence with documentary support; if penalty is levied, appeal under Section 246A(1)(q) before CIT(A) (NFAC); further appeal to ITAT Chennai bench; engage a Chennai TDS-specialist lawyer for higher courts.

What is the cost of engaging a TDS notice reply consultant in Chennai?

FilingPro Chennai charges fixed fees by complexity tier — Section 200A intimation rectification from ₹4,500; Section 201 reply from ₹18,000; Section 271C/271H penalty defence from ₹25,000; appellate work before CIT(A) (NFAC) and ITAT priced per stage. Contact Mannady office for engagement.

Does Madras High Court accept writs against Section 200A intimations?

Generally no — the standard route is Section 154 rectification before CPC-TDS followed by Section 246A appeal before CIT(A) (NFAC). Madras HC entertains writs only where jurisdictional defects (limitation, absence of authority) or breach of natural justice are apparent on the face of the record.

What is the priority order for replying to multiple TDS notices?

Address Section 156 demand notices first (recovery risk), then Section 271C/271H/276B penalty/prosecution notices (mens-rea defence record), then Section 201 show-cause (substantive merits), then Section 200A rectifications (processing-level). File Form 26A in parallel to neutralise primary liability.

What is a Section 200A intimation?

A Section 200A intimation is the automated processing communication issued by CPC-TDS after processing your TDS statement. It validates arithmetic, matches challans, computes Section 234E late-filing fee and Section 201(1A) interest, and surfaces short-payment or mismatch demands.

What Pattabiram clients want to know before signing: Closer to Pattabiram, on the Avadi-Tirumullaivoyal corridor that passes through Pattabiram, which is why with most filings in this catchment being personal income-tax returns under ITR-1 to ITR-3 and one-off TDS reconciliations.

Expert Guide

A complete walkthrough — Tds Notice Reply

Localised for Pattabiram, Chennai — where ancillary contractors serving defence establishments file GST TDS under Section 51 and operate on DGS&D rate-contracts.

Reading this guide locally — In Pattabiram, in the defence and residential mixed micro-market of Pattabiram; Pattabiram businesses in the defence arm find that businesses serve a captive customer base under Section 51 GST TDS DGS&D rate contracts and quarterly 26Q filings.

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 271H penalty for non-filing or false particulars

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.

Section 273B reasonable-cause relief

Section 273B operates as an overlay on Section 271H — even where the safe-harbour under 271H(3) is unavailable, the penalty cannot be imposed if the deductor shows reasonable cause for the failure. Reasonable cause has been judicially construed to include — system-level TRACES outage substantiated by TIN-NSDL acknowledgement, statutory auditor's strike preventing finalisation, key-person illness or demise with hospital records, and tax-credit-pending-reconciliation with the deductee that legitimately delayed filing. The defence is fact-intensive and the documentary trail must be contemporaneous. The Supreme Court in Hindustan Steel underpins the principle that technical or venial breach should not attract penalty.

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.

Section 220 interest and the 30-day recovery window

Statutory text and triggers

Sub-section (1) of Section 220 provides that any amount specified as payable in a notice of demand under Section 156 shall be paid within thirty days of the service of the notice at the place and to the person mentioned in the notice. Sub-section (2) provides that on default the assessee shall be liable to pay simple interest at 1% per month on the amount remaining unpaid. The 30-day clock starts on service of the demand notice, not on the date of the underlying order. Sub-section (3) empowers the Assessing Officer, on application before expiry of 30 days, to extend the period or allow payment in instalments — a power frequently underused by Chennai deductors.

Stay of demand and CBDT Instruction 1914

CBDT Instruction 1914 dated 02-Dec-1993 as updated by Office Memorandum dated 29-Feb-2016 and 31-Jul-2017 provides the administrative framework for stay of demand pending first appeal. The current default position requires payment of 20% of disputed demand for grant of stay, with discretionary lower amounts where the assessment is in an obviously hostile direction relative to settled jurisprudence. The Bombay HC in UTI Mutual Fund and the Delhi HC in Mrs Kannammal v ITO held that the 20% is not a rigid rule and the AO must record reasons before insisting on full payment. A reasoned representation under the OM framework, filed before the 30-day expiry, is essential.

Section 220(6) and pendency of appeal

Sub-section (6) of Section 220 provides that where an assessee has presented an appeal under Section 246A, the Assessing Officer may in his discretion, and subject to such conditions as he may think fit, treat the assessee as not being in default in respect of the amount in dispute, even though the time for payment has expired, until the appeal is disposed of. The discretion under 220(6) is independent of the Instruction 1914 framework — it is a statutory grant. The Supreme Court in KEC International v B.R. Balakrishnan held that the AO's discretion under 220(6) is to be exercised judiciously. A standalone 220(6) application filed alongside the Section 246A appeal is the procedurally correct route.

Section 40(a)(ia) and 40(a)(i) disallowance interplay

Non-resident payments and 100% disallowance

Section 40(a)(i) on non-resident payments carries a steeper disallowance — 100% of the expenditure — and the relief framework is correspondingly narrower. The first proviso to Section 40(a)(i) permits deduction in the subsequent year on actual payment of TDS. The second proviso analogous to 40(a)(ia) covers Form 26A relief but the make-available test for chargeability and the DTAA-rate-cap analysis become central. The Supreme Court in GE India Technology Centre held that Section 195 obligation is triggered only where the payment is chargeable to tax in India under Sections 4, 5 and 9 — non-chargeability defeats both 195 and consequential 40(a)(i).

Statutory text and operation

Section 40(a)(ia) disallows 30% of any sum payable to a resident on which tax was deductible at source but has not been deducted, or having been deducted has not been paid on or before the due date specified in Section 139(1). Section 40(a)(i) operates analogously on non-resident payments but at 100% disallowance — the entire expenditure stands disallowed. The Memorandum to Finance Bill 2014 explained the reduction of resident disallowance from 100% to 30% as a rationalisation measure. The Supreme Court in Palam Gas Service Hindustan Coca-Cola Beverages ruling clarified that 40(a)(ia) operates on the date of payment of TDS, not on the date of deduction, where deduction was made.

First and second provisos to Section 40(a)(ia)

The first proviso to Section 40(a)(ia) permits deduction of the disallowed expenditure in the subsequent year in which the TDS is actually paid. The second proviso, inserted by Finance Act 2012 with effect from 01-Apr-2013, provides that where the deductee has paid tax under Section 201 first proviso (i.e. through Form 26A) the deductor is not deemed to be in assessee-in-default and consequently the 40(a)(ia) disallowance does not attach. The Mumbai ITAT in JDS Apparels and Delhi ITAT in Ansal Land Mark held that Form 26A acceptance simultaneously defeats both 201(1) principal and 40(a)(ia) disallowance.

What Pattabiram clients usually ask next: Closer to Pattabiram, supporting the defence-establishment civilian workforce that lives in the surrounding cantonment-friendly housing, which is why where ancillary contractors serving defence establishments file GST TDS under Section 51 and operate on DGS&D rate-contracts; for the professional and salaried population of Pattabiram navigating personal-tax and home-office GST.

Glossary

Plain-English glossary for this service

Terms you will hear in this area — In Pattabiram, where ancillary contractors serving defence establishments file GST TDS under Section 51 and operate on DGS&D rate-contracts.

Section 201(1A)(ii) Interest

Section 201(1A)(ii) Interest is the one-and-a-half per cent per month interest charged from the date of deduction to the date of deposit, payable by a deductor who deducted TDS but failed to deposit it on time. It is not relieved by Form 26A since the deductor has admitted holding government money and remains payable in full.

Section 234E Late-Filing Fee

Section 234E Late-Filing Fee is the levy of two hundred rupees per day for every day the TDS statement is filed after the Section 200(3) due date, capped at the TDS amount. Section 200A(1)(c) authorising the 234E adjustment through Section 200A intimation was inserted only w.e.f. 01-Jun-2015 by Finance Act 2015 — pre-amendment levies are quashable on Fatehraj Singhvi.

Section 271H Penalty

Section 271H Penalty is the ten-thousand-to-one-lakh-rupee penalty for failure to file a TDS statement or for filing an incorrect statement. Section 271H(3) gives full immunity where the deductor deposits the TDS, applicable interest and Section 234E fee, and files the statement, within one year of the due date.

Section 276B Prosecution

Section 276B Prosecution is the criminal prosecution provision for failure to pay deducted TDS to the credit of the Central Government — imprisonment from three months to seven years with fine. Compounding is available under CBDT Guidelines dated 17-Oct-2024 on payment of admitted tax, interest, fee and compounding fee at two per cent per month on the principal TDS for the default period.

Section 206AA

Section 206AA is the higher-rate deduction provision triggered when the payee does not furnish PAN, or furnishes a structurally invalid PAN, or has an inoperative PAN-Aadhaar status. TDS is deducted at the higher of the rate in force, the rate specified in the relevant section, or twenty per cent. It overrides DTAA rates per Bosch (Bangalore ITAT 2018) line.

Section 206AB Compliance Check

Section 206AB Compliance Check is the higher-rate deduction at twice the applicable rate or five per cent (whichever is higher) on payments to specified persons who have not filed ITR for the prior assessment year and have aggregate TDS or TCS of fifty thousand rupees or more. Compliance Check facility on the income-tax portal lets the deductor verify status before each payment.

PAN-Aadhaar Inoperative Status

PAN-Aadhaar Inoperative Status arises where the PAN holder has failed to link Aadhaar by the deadline prescribed in CBDT Circular 3 of 2023. An inoperative PAN is treated as if PAN has not been furnished, triggering Section 206AA twenty per cent. Linking after the deadline cures the status only prospectively per CBDT Circular 6 of 2024.

BIN Number

BIN or Book Identification Number is the seven-digit number generated for government deductors who pay TDS through book adjustment rather than challan. It is reported in Form 24G by the Accounts Officer and quoted in the Form 24Q / 26Q deductor entry. BIN mismatches between Form 24G and the TDS statement are a common Default Rectification Request scenario.

CIN Number

CIN or Challan Identification Number is the combined identifier of BSR Code (7 digits) + Date of Deposit (DDMMYYYY) + Challan Serial Number (5 digits) printed on the bank counterfoil for an OLTAS challan. It is the primary reference for challan tagging in TDS statements through Online Correction Category C-2.

TAN-PAN Linkage

TAN-PAN Linkage is the mapping between the deductor's Tax Deduction Account Number and Permanent Account Number maintained at NSDL. A correct linkage is required for Section 197 lower-deduction certificate applications, Section 195 Form 15CA / 15CB filings, and for the deductor's income-tax 26AS credit on TDS deducted from its own receipts.

Section 197 Lower-Deduction Certificate

Section 197 Lower-Deduction Certificate is the certificate issued by the AO TDS authorising the deductor to deduct TDS at a lower rate, or nil, on payments to a specific deductee, where the deductee has demonstrated that his projected income justifies a lower rate. Applied online in Form 13 through TRACES with twelve-month validity within the same FY.

Form 15CA and 15CB

Form 15CA is the deductor's declaration filed online on the income-tax portal before a foreign remittance, and Form 15CB is the accompanying Chartered Accountant certificate where the remittance exceeds five lakh rupees in the FY and is chargeable to tax. The pair operationalises Section 195 / Rule 37BB for non-resident TDS compliance.

Cost of Non-Compliance

Real-world penalty exposure

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

Penalty exposure typical of this micro-market — In Pattabiram, Pattabiram businesses in the defence arm find that businesses serve a captive customer base under Section 51 GST TDS DGS&D rate contracts and quarterly 26Q filings; supporting the defence-establishment civilian workforce that lives in the surrounding cantonment-friendly housing.

ScenarioBase taxInterestPenaltyTotal
Section 194-O e-commerce TDS non-deduction by operator on ₹50 lakh GMV — Section 271C₹5,000 (0.1 per cent post Oct 2024)₹900 (18 months)₹5,000 (Section 271C)₹10,900
Section 194LBA non-deduction by Business Trust on unitholder distribution of ₹40 lakh — Section 271C₹4,00,000 (10 per cent on resident interest)₹72,000 (18 months)₹4,00,000 (Section 271C)₹8,72,000
Section 200A intimation — Section 234E only, 45-day delay, TDS ₹3 lakh₹0₹0₹9,000 (Section 234E at ₹200 × 45 days)₹9,000
Section 201(1A) interest-only — late deposit of ₹10 lakh TDS by 60 days₹10,00,000 (already paid)₹30,000 (2 months at 1.5 per cent)₹0 (interest only, no penalty if Section 271C avoided)₹30,000
Section 194I non-deduction on rent of ₹6 lakh paid by company — Section 271C₹60,000 (10 per cent for land/building)₹10,800 (18 months)₹60,000 (Section 271C)₹1,30,800
Section 194-IC non-deduction on JDA monetary consideration of ₹30 lakh — Section 271C₹3,00,000 (10 per cent)₹54,000 (18 months)₹3,00,000 (Section 271C)₹6,54,000

How Pattabiram businesses typically avoid these: Closer to Pattabiram, the cluster of defence, residential, logistics businesses that defines Pattabiram's commercial fabric, which is why for the professional and salaried population of Pattabiram navigating personal-tax and home-office GST.

By Industry

Industry-specific patterns in Pattabiram

How the local trade mix shapes this — In Pattabiram, with most filings in this catchment being personal income-tax returns under ITR-1 to ITR-3 and one-off TDS reconciliations; the cluster of defence, residential, logistics businesses that defines Pattabiram's commercial fabric.

Logistics
Common issue: Freight forwarders paying foreign shipping lines container charges under Section 172 read with Section 194C face confusion at TRACES — the freight is exempt from TDS where the shipping line files a Section 172(7) return, but absent that filing the default crystallises.
How we handle it: Furnish the foreign shipping line's voyage-return acknowledgement, the Section 172(4) Master order or the Mumbai ITAT ruling on Section 172 overriding Chapter XVII-B. Where the shipping line has not filed Section 172 return, regularise prospectively and contest only the principal head citing Orient Goa Pvt Ltd Bombay HC.
Logistics
Common issue: Goods-transport operators with PAN-Aadhaar linkage furnish a Section 194C(6) declaration claiming nil deduction since they own fewer than ten goods carriages. Deductors who accept this declaration without verification get hit with Section 201 demands when the carrier owns more than ten vehicles.
How we handle it: Validate the 194C(6) declaration with Vahan-portal extract showing fleet count, transporter PAN on TRACES Annexure-I and quarterly recap. Where the declaration turned out false, the principal liability is on the deductor under Section 201(1) but the recovery right under Section 191 transfers to the carrier — pursue both heads.
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.
Engineering
Common issue: Project-engineering firms paying foreign supervisory-engineer charges treat the payment as reimbursement of salary cost. CPC-TDS however raises Section 195 default treating the cross-charge as fees for technical services with make-available element.
How we handle it: Where the supervisory engineer was seconded under a true secondment arrangement with the Indian entity as economic employer, the payment is salary in the engineer's hands subject to Section 192. Cite the Centrica India Supreme Court ruling on secondment and place evidence of Form 16 issued by the Indian entity.
Case Studies

Anonymised engagements we have handled

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

A flavour of cases we handle nearby — In Pattabiram, where ancillary contractors serving defence establishments file GST TDS under Section 51 and operate on DGS&D rate-contracts; Pattabiram businesses in the residential arm find that professional services from this area mostly fall under Section 194J 194C TDS on freelancers and personal-IT filings under ITR-1 to ITR-3.

Section 194-ORetail

Section 201 — payment to e-commerce operator under 194-O

Issue: A Chennai retail seller using a major e-commerce platform received Section 201 show-cause for short-deduction under Section 194-O contending that the e-commerce operator had under-deducted at 0.1 per cent against the prescribed 1 per cent for the period before the Finance Act 2024 rate reduction to 0.1 per cent took effect on 1 Oct 2024.
Approach: Filed written submissions identifying that the seller was not the deductor under Section 194-O — the obligation rests on the e-commerce operator (the platform). Argued that the seller had no deduction obligation under Section 194-O and could not be treated as an assessee-in-default. Filed the platform's TDS certificate showing the deduction at the rate determined by the platform. Cited the legislative framework that Section 194-O is operator-side, not seller-side.
Outcome: AO dropped the Section 201 proceedings against the seller; the show-cause was wrongly directed; client clarified its position; SOP for platform-mediated sales documented.
Section 194C(6) transporterLogistics

Section 201 — TDS on payment to transporter under Section 194C(6)

Issue: A logistics company did not deduct TDS on payments aggregating ₹84 lakh to small transport operators relying on the Section 194C(6) exemption for transporters owning ten or fewer goods carriages. The AO (TDS) issued Section 201 show-cause contending that the operator PAN declarations under Section 194C(6) were defective.
Approach: Filed all 47 transporter declarations with PAN, vehicle-ownership particulars and the requisite contents per Rule 31A(5). Where some declarations were incomplete, obtained fresh declarations retrospectively and produced them with a covering note. Relied on ITAT rulings that minor procedural defects in Section 194C(6) declarations are curable and do not defeat the substantive exemption where the underlying conditions are met.
Outcome: AO accepted the corrected declarations; Section 201 dropped for 41 of 47 transporters; residual short-deduction of ₹1.8 lakh sustained where transporters could not provide declarations; total saving ₹14.6 lakh.
Section 226(3) attachmentRetail

Section 156 demand — recovery via Section 226(3) attachment

Issue: A Chennai retail firm received a Section 226(3) garnishee notice attaching ₹14 lakh in its current account towards a Section 201 demand under Section 156. The firm had not paid the demand pending appeal under Section 246A but had failed to file a Section 220(6) stay application.
Approach: Immediately filed Section 220(6) stay application before the AO citing CBDT OM benchmark of 20 per cent pre-deposit, paid ₹2.8 lakh, and obtained AO stay within 7 days. Followed up with a writ before Madras HC seeking immediate release of the garnisheed amount on the basis that the attachment, having pre-dated the stay, was now without statutory basis. The HC ordered release of ₹11.2 lakh while preserving the AO's right to enforce the unpaid 80 per cent post-appeal.
Outcome: ₹11.2 lakh released within 21 days of the writ order; appeal continues before CIT(A) (NFAC); client preserved the precedent and now files Section 220(6) within 30 days of every Section 156 demand as a standard step.
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.

Why these Pattabiram engagements look the way they do: Closer to Pattabiram, the cluster of defence, residential, logistics businesses that defines Pattabiram's commercial fabric, which is why for the professional and salaried population of Pattabiram navigating personal-tax and home-office GST.

Client Reviews

What Pattabiram 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 — Pattabiram

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

The first proviso to Section 201(1) (inserted by Finance Act 2012, w.e.f. 01-Jul-2012) — codifying CIT v. Hindustan Coca-Cola Beverages Pvt Ltd [2007] 293 ITR 226 (SC) — provides that the deductor shall NOT be deemed to be in default if the resident payee (i) has furnished his return of income under Section 139, (ii) has taken into account such sum for computing income in such return, (iii) has paid the tax due on the income declared, and (iv) the deductor furnishes a certificate to this effect from a Chartered Accountant in Form 26A (Annexure A). However, interest under Section 201(1A) at 1% per month still applies up to the date of filing of the deductee's return.
Section 197 read with Rule 28 allows a payee to apply in Form 13 to the AO for a certificate authorising lower or nil TDS where the payee's estimated tax liability justifies it. The certificate is prospective only — once issued, the deductor relies on it for that specific deductor-deductee-section combination. It cannot regularise past short-deduction defaults retrospectively but is the strategic tool for future quarters where the deductee's effective rate is structurally lower than the statutory TDS rate.
Pattabiram (PIN 600072) falls under the Avadi Division, Chennai West 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 Pattabiram engagement.
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.
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.
Turnaround depends on the service and how quickly you share documents. Once we have a complete set, TDS Notice Reply for Pattabiram clients moves without avoidable delay, and we keep you posted at each stage. We give a realistic timeline upfront rather than an optimistic one.
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.
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).
Yes. We handle TDS Notice Reply for salaried individuals, proprietors, partnerships, LLPs and private limited companies across Pattabiram. Whatever your structure, we scope the TDS Notice Reply work to fit it — call 9566-068-468 to discuss yours.
Where Form 26A is filed, the first proviso to Section 201(1A) (read with the first proviso to Section 201(1)) limits interest at 1% to the period from date of deductibility to the date of furnishing of return by the resident payee. After that date, no interest accrues since the deductor is no longer in default. The Justification Report does NOT auto-apply this — manual computation + Form 26A filing is required to claim the truncated interest period.
Section 206AB (inserted by Finance Act 2021, w.e.f. 01-Jul-2021) prescribes higher TDS rate (twice the rate in force or 5%, whichever higher) for "specified persons" who have not filed return for the immediately preceding AY where TDS in their case is ₹50,000 or more. The deductor checks status on the "Compliance Check for Section 206AB & 206CCA" utility on the Reporting Portal. Short-deduction default under 206AB is defended by producing the Compliance Check screenshot proving deductee was not specified person at the time of payment.
No. The TDS Notice Reply fee we quote upfront is the fee you pay — any government fees or third-party charges are shown separately and explained in advance. Pattabiram clients get full transparency before committing.
For government deductors who pay TDS by Book Adjustment (no challan), the Pay & Accounts Office (PAO) / Treasury Officer files Form 24G monthly under Rule 30(4). The PAO assigns a Book Identification Number (BIN) — Receipt No. + DDO Sl. No. + Date of Transfer — which the DDO uses in the TDS statement instead of CIN. Mismatch between Form 24G and TDS statement BIN is the leading cause of short-payment defaults for govt deductors. Reconciliation through TRACES BIN View > 24G Statement Status is the remedy.
Section 206AA mandates TDS at the higher of (a) the rate prescribed under the relevant section, (b) the rate in force, or (c) 20%, where the deductee has not furnished his PAN. For non-residents, the AAR and several ITATs have held that Section 90(2) overrides Section 206AA where DTAA rate is lower (Serum Institute, Wipro Ltd, Nagarjuna Fertilizers). For residents, 20% is mandatory and short-deduction default is unavoidable unless PAN is subsequently corrected through Online Correction (C-3 challan-based or C-9 PAN correction).
Interest under Section 201(1A) is computed on monthly basis — any part of a month is treated as a full month. Example: tax deductible on 15-Apr-2024, deducted on 03-May-2024 (delay one day in April + 3 days in May = 2 months × 1% = 2%). Tax deducted 03-May-2024, deposited 09-Jun-2024 (delay one part-month in May + one part-month in June = 2 months × 1.5% = 3%). The TRACES Justification Report applies this rule mechanically.
For payments to non-residents, the deductor's TDS obligation under Section 195 arises only if the sum is "chargeable under the provisions of this Act" — GE India Technology Centre v. CIT [2010] 327 ITR 456 (SC) holds that mere payment is not sufficient; chargeability under Sections 5/9 read with DTAA must exist. Common defences: (i) pure reimbursement, (ii) software licence not royalty post Engineering Analysis (SC 2021), (iii) FTS not satisfying "make available" test in DTAA Article 12/13, (iv) business profits without PE under DTAA Article 7. If chargeability fails, Section 201/40(a)(i) cannot be sustained.
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