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TDS Default & TRACES Notice Defence · St Thomas Mount

St Thomas Mount TDS Notice Reply for hospitality Businesses

End-to-end TDS Notice Reply for St Thomas Mount commercial residential mix with airport proximity establishments — handled by a qualified, in-house team

TDS Notice Reply for commercial residential mix with airport proximity businesses across the St Thomas Mount pocket near Mount Railway Station with on-time portal submission and full statutory reconciliation. Call 9566-068-468.

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Quick Answer

What documents does the C.A. need to issue Form 26A Annexure A in St Thomas Mount, Chennai?

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.

Transparent Pricing

TDS Notice Reply in St Thomas Mount — 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 St Thomas Mount Clients Choose FilingPro

Expert TDS Notice Reply in St Thomas Mount — 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 St Thomas Mount 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 St Thomas Mount 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 St Thomas Mount 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 — In St Thomas Mount, the business activity radiating outward from St Thomas Mount Cantonment and nearby commercial pockets; with quick access via St Thomas Mount Metro and feeder routes connecting St Thomas Mount to the rest of Chennai.

AspectSection 200A IntimationSection 201 Default Order
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
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
Documents Required

Documents for TDS Notice Reply

Share documents via WhatsApp to 9566-068-468. No office visit required for St Thomas Mount 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 St Thomas Mount, the cluster of hospitality, aviation, logistics businesses that defines St Thomas Mount'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
Quarterly TDS statement due date — first quarter31 daysForm 24Q or Form 26Q as applicableSection 234E fee of two hundred rupees per day commences

Deadline pressure points we see in St Thomas Mount: For St Thomas Mount engagements specifically — for St Thomas Mount IT-services firms managing export-LUT cycles alongside payroll and TDS.

Forms Library

Forms used in this engagement

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
Form 16Certificate of tax deducted at source from salary

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

By the fifteenth day of June of the financial year immediately following the year of deduction Issued by the deductor-employer to the employee

TDS Notice Reply in St Thomas Mount, Chennai 600016

St Thomas Mount (PIN 600016) falls under the Saidapet Division of the Chennai South, the jurisdiction that handles statutory matters for businesses at this PIN. Approvals, acknowledgements and queries for St Thomas Mount businesses tie back to the Saidapet Division, so our TDS Notice Reply cadence accounts for how that office works. Because PIN 600016 sits inside the Chennai South jurisdiction, the handling office for St Thomas Mount stays consistent across years, which matters when filings or approvals span cycles. The 600xx geo-zone covering St Thomas Mount groups several locality clusters under common administration, keeping documentation expectations predictable.

Commercial activity in St Thomas Mount runs high, so TDS Notice Reply volumes scale through peak months and we staff the St Thomas Mount desk accordingly. Each TDS Notice Reply cycle for St Thomas Mount reflects its commercial rhythm — invoices generated near Chennai Airport, expenses routed through the St Thomas Mount Metro freight network. Most commerce in St Thomas Mount — invoices, expenses, purchases and statutory records — eventually surfaces in the TDS Notice Reply working file we maintain for clients here. St Thomas Mount sustains a high flow of commerce for a commercial residential mix with airport proximity locality, and that flow is the raw material for the TDS Notice Reply files we close here.

For a hospitality business in St Thomas Mount, the TDS Notice Reply scope is rarely generic; we tailor the checklist to how that sector actually transacts. hospitality units around St Thomas Mount share recurring TDS Notice Reply patterns — input-credit timing, vendor reconciliation, and sector-specific documentation. The hospitality character of St Thomas Mount commerce influences everything from invoice formats to the supporting documents a TDS Notice Reply review needs. TDS Notice Reply for hospitality businesses in St Thomas Mount hinges on getting the sector's recurring entries right the first time.

A St Thomas Mount client sees the same TDS Notice Reply cadence each cycle: intake, reconciliation, review, filing, acknowledgement. The St Thomas Mount TDS Notice Reply workflow is documented end-to-end: WhatsApp document intake, a working file, qualified review, and a filed acknowledgement back to you. Working papers for St Thomas Mount TDS Notice Reply engagements stay archived and retrievable, which makes any later notice or query straightforward to answer. The qualified-review step on every St Thomas Mount TDS Notice Reply file is where errors get caught before they reach the portal.

We treat St Thomas Mount and Guindy as one catchment for TDS Notice Reply, which keeps documentation and turnaround consistent. Serving St Thomas Mount and Guindy from one team keeps TDS Notice Reply turnaround identical across the cluster. Coverage from St Thomas Mount naturally extends to Guindy, so group entities across the area share one TDS Notice Reply workflow. A client relocating between St Thomas Mount and Guindy keeps the same TDS Notice Reply file and the same team.

Patterns we track for St Thomas Mount include logistics documentation gaps, timing mismatches, and the questions the Saidapet Division tends to raise. Because we work repeatedly across St Thomas Mount, we can benchmark a new client's TDS Notice Reply position against the locality norm. The TDS Notice Reply mistakes we see most in St Thomas Mount are avoidable with disciplined intake, which our checklist enforces. The longer we serve St Thomas Mount, the more precisely we predict where a TDS Notice Reply file needs attention.

For a new business incorporating in St Thomas Mount or shifting its principal place of business here, TDS Notice Reply setup is one of the first things to get right. When a Nandambakkam business expands into St Thomas Mount, we extend its TDS Notice Reply setup to PIN 600016 without disruption. Shifting principal place of business to St Thomas Mount means updating jurisdiction to the Chennai South, and we manage the paperwork end-to-end. We onboard new St Thomas Mount entities onto a TDS Notice Reply cadence that is audit-ready from the very first cycle.

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Expert Guide

TDS Notice Reply in St Thomas Mount — Complete Guide

TDS Notice Reply for St Thomas Mount (600016) deductors is handled end-to-end at FilingPro — Section 200A CPC-TDS intimation, Section 201(1) deemed-default order, Section 201(1A) interest at 1% / 1.5% per month, Section 234E ₹200/day late fee and Section 271H penalty. The TRACES Justification Report is downloaded on day one, every default head — short payment, short deduction, interest and fee — is mapped to a defence, and the appropriate remedy (Online Correction C-1 to C-9, Default Rectification Request, Form 26A Annexure-A, or full reply with case law) is filed within the 30-day Section 220 recovery window.

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Qualified professionals handle your TDS Notice Reply in St Thomas Mount. WhatsApp documents — we begin within 24 hours. From ₹2,500/per-notice. Free consultation.
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Key Facts — TDS Notice Reply in St Thomas Mount
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 St Thomas Mount
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.
How do I file a correction statement on TRACES?

Log in to TRACES, navigate to 'Statements/Payments — Request for Correction', select the statement type and quarter, download the consolidated file, edit in the TDS-CPC utility, sign with DSC, upload corrected file. Allow 7-10 days for processing.

What is the Section 234E cap for late-filing fee?

Section 234E fee at ₹200 per day of delay is capped at the total TDS amount of the relevant statement. The cap operates per statement (per Form 24Q/26Q/27Q) and per quarter; thus the per-statement maximum equals the statement's underlying TDS sum.

Can I appeal Section 234E levy?

Yes, where the levy adjudicates more than mere arithmetic (e.g. interest computation under Section 201(1A) is also included), appeal lies under Section 246A(1)(a) before CIT(A) (NFAC) within 30 days. Pure Section 234E levies are largely settled and not amenable to appeal.

What is the Goetze v CIT principle relevant to TDS replies?

The Supreme Court in Goetze (India) v CIT held that fresh claims cannot be made before the AO except by a revised return. In TDS replies, this means deductee tax-credit corrections must flow through correction statements, not by mere AO submissions.

How does Section 226(3) garnishee attachment work for TDS demand?

Section 226(3) allows the AO to issue notice to debtors (banks, customers) of the deductor requiring them to pay the deductor's debts directly to the department. File Section 220(6) stay application immediately to halt the attachment; writ to Madras HC for release.

What documents should I file with a Section 201 reply?

Show-cause reply, deductee Form 26A certificates, contracts/agreements clarifying the nature of payment, prior assessment orders for the same payment-type, CA opinion (if relied on), TDS challans, statement of facts, and a tabulated submission of Section 273B reasonable-cause grounds.

What St Thomas Mount clients want to know before signing: For St Thomas Mount engagements specifically — around the St Thomas Mount Cantonment catchment of St Thomas Mount.

Expert Guide

A complete walkthrough — Tds Notice Reply

Reading this guide locally — In St Thomas Mount, on the Guindy-Alandur corridor that passes through St Thomas Mount.

What is a TDS notice and the architecture of TDS enforcement

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.

Five categories of TDS communications

TDS communications received by Chennai deductors broadly fall into five categories distinguishable by their statutory anchor. First, Section 200A(1) intimations are issued by the Centralised Processing Cell-TDS at Vaishali Ghaziabad on prima-facie defaults identified during return-processing. Second, Section 201(1) default orders are issued by jurisdictional Assessing Officer (TDS) on substantive non-deduction or short-deduction post-enquiry. Third, Section 234E demand notices arise from late-filing fee at ₹200 per day of delay. Fourth, Section 271H penalty notices follow non-filing exceeding one year or false-particulars. Fifth, Section 220 recovery and Section 221 penalty notices follow non-payment beyond 30 days. Each category invokes a distinct response framework, distinct limitation period and distinct appellate route — conflating them is the single most common defence error observed in the Madras ITAT TDS-Bench rulings since 2018.

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).

Section 234E late-filing fee — challenge points

Procedural challenge through Section 154

Since Section 234E fee is levied via Section 200A intimation, the rectification remedy under Section 154 is available where the levy contains a mistake apparent from the record. Such mistakes include — fee levied for the period prior to 01-Jun-2015 (post Fatehraj Singhvi where applicable bench), fee exceeding the tax-deductible cap, fee levied where the statement was filed within the due-date but acknowledged late on TRACES owing to portal failure, and fee continued despite a notified CBDT extension. The Section 154 application must be filed within four years from the end of the financial year in which the order was passed. Where 154 is rejected, the appeal route under Section 246A is available.

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.

Section 271H penalty for non-filing or false particulars

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.

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.

Section 220 interest and the 30-day recovery window

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 221 penalty and waiver

Section 221 empowers the Assessing Officer to impose a penalty not exceeding the amount of tax in arrears for default in payment of tax under Section 220. The proviso to Section 221(1) requires the AO to give a hearing before imposition. Sub-section (1) second proviso allows waiver of penalty where the assessee proves that the default was for good and sufficient reasons — typically a pending appeal, bona-fide stay application, business-cash-flow distress with bank confirmations, or genuine inability arising from non-receipt of refunds due to the assessee. The Madras HC in Tamil Nadu Mercantile Bank set out the threshold for good-and-sufficient-reasons defence under 221.

What St Thomas Mount clients usually ask next: For St Thomas Mount engagements specifically — for St Thomas Mount IT-services firms managing export-LUT cycles alongside payroll and TDS.

Glossary

Plain-English glossary for this service

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.

Form 24Q Annexure II

Form 24Q Annexure II is the year-end salary detail annexure filed only with the Q4 24Q statement, containing employee-wise salary breakup, Section 10 exemptions, Section 16 standard deduction, Chapter VI-A deductions and tax computation. Errors in Annexure II are the most common Section 271H incorrect-statement triggers and require Online Correction Category C-5.

Cost of Non-Compliance

Real-world penalty exposure

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

ScenarioBase taxInterestPenaltyTotal
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
Form 26Q inaccurate particulars — 6 deductee PANs incorrect — Section 271H₹0₹0₹60,000 (₹10,000 × 6 errors)₹60,000
Section 194B TDS non-deduction on lottery winnings of ₹3 lakh — Section 271C₹90,000 (30 per cent)₹16,200 (18 months)₹90,000 (Section 271C)₹1,96,200
Section 194R non-deduction on benefits/perquisites of ₹4 lakh to dealers — Section 271C₹40,000 (10 per cent)₹7,200 (18 months)₹40,000 (Section 271C)₹87,200
Section 194S non-deduction on virtual digital assets transfer of ₹20 lakh — Section 271C₹20,000 (1 per cent)₹3,600 (18 months)₹20,000 (Section 271C)₹43,600

How St Thomas Mount businesses typically avoid these: For St Thomas Mount engagements specifically — the business activity radiating outward from St Thomas Mount Cantonment and nearby commercial pockets; for St Thomas Mount IT-services firms managing export-LUT cycles alongside payroll and TDS.

By Industry

Industry-specific patterns in St Thomas Mount

How the local trade mix shapes this — In St Thomas Mount, the business activity radiating outward from St Thomas Mount Cantonment and nearby commercial pockets.

Hospitality
Common issue: Hotels and serviced-apartment operators paying online travel aggregator commissions under Section 194H at 5% receive default notices when CPC-TDS reclassifies the commission as Section 194-O e-commerce participant payment at 1%, creating a notional short-deduction of 4% even though excess was deducted.
How we handle it: The defence is a procedural one — the deductor cannot be in default for over-deduction; the issue is one of refund mechanism for the excess. File reply citing the Section 194-O Explanation and CBDT Circular 17/2020 along with deductee invoice-level reconciliation. Seek default-NIL on the 4% gap and migrate prospective deductions to 194-O.
Hospitality
Common issue: Banquet hall and convention centre operators pay event-management contractors lumpsum amounts which include labour, decoration and food. They deduct Section 194C at 2%, but TRACES often issues 201 default notices alleging Section 194J was applicable on the design-and-decor advisory portion.
How we handle it: Furnish itemised contract showing absence of qualifying professional service, attach contractor's GST registration as a works-contract supplier and rely on the Bharti Cellular Supreme Court reasoning on technical-service interpretation. Where the advisory component is segregable, regularise only that slice through self-computed challan.
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.
Case Studies

Anonymised engagements we have handled

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

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.
Section 234E pre-Jun-2015Hospitality

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

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

Why these St Thomas Mount engagements look the way they do: For St Thomas Mount engagements specifically — the cluster of hospitality, aviation, logistics businesses that defines St Thomas Mount's commercial fabric; for St Thomas Mount IT-services firms managing export-LUT cycles alongside payroll and TDS.

Client Reviews

What St Thomas Mount 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 — St Thomas Mount

Common questions from St Thomas Mount clients. Call 9566-068-468 for specific queries.

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.
Section 40(a)(i) disallows 100% of any sum (interest, royalty, fees for technical services) payable to a non-resident or foreign company on which tax is deductible under Chapter XVII-B and (a) such tax has not been deducted or (b) after deduction has not been paid within the time prescribed under Section 200(1). Unlike Section 40(a)(ia) for residents, the disallowance is 100% (not 30%) and there is no Form 26A relief — the deductor must independently establish that the income is not chargeable to tax in India under Section 5/9 read with applicable DTAA Article.
Very likely yes — St Thomas Mount has a commercial residential mix with airport proximity profile where hospitality and allied activity creates exactly the compliance needs TDS Notice Reply addresses. We see these requirements here often and handle them efficiently. If it does not apply to you, we will say so.
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).
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.
St Thomas Mount (PIN 600016) falls under the Saidapet Division, Chennai South commissionerate. Getting the jurisdiction right matters because registrations, filings and notices are routed through the correct office. We confirm and handle the right jurisdiction for every St Thomas Mount engagement.
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.
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).
Yes. We do not disappear after filing — St Thomas Mount clients can come back to us for follow-up questions, notices or renewals tied to their TDS Notice Reply. Ongoing support is part of how we work, not a paid extra for routine 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.
Form 26A is the C.A. certificate for TDS defaults under Section 201(1) first proviso — covers deductor's relief from being in default for failure to deduct under Sections 192-195. Form 27BA is the parallel certificate for TCS defaults under Section 206C(6A) first proviso — covers collector's relief for failure to collect under Section 206C. Both are filed on TRACES through the same module (Statements > Request for 26A/27BA) and signed digitally by a practicing C.A.
Your engagement is handled by our in-house team led by Ravivarman R (Founder, 15+ years, 500+ engagements), with M. E. Chokkalingam on compliance and S. Jayaprakash on GST matters. You deal with named, qualified people throughout your TDS Notice Reply — not a call centre.
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.
TRACES Online Correction module supports nine categories: C-1 Challan Correction (move challan from one Quarter / FY); C-2 Add Challan to Statement; C-3 Personal Information Correction (deductor); C-4 Salary Detail Correction (24Q Annexure II); C-5 Deductee Detail Correction (rate, amount); C-6 Movement of deductee row across challans; C-7 PAN-Aadhaar Correction; C-8 Add Challan with deductee row; C-9 PAN Correction in deductee detail. Each correction generates a fresh Conso File and revised Justification Report.
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.
Defence sequence: (1) characterise payment under Section 9(1)(vi) royalty / 9(1)(vii) FTS — apply Explanation 2 (royalty) and Explanation 2 (FTS); (2) invoke Section 90(2) — apply DTAA Article 12 "make available" test (India-US, India-UK, India-Singapore DTAAs); (3) cite Engineering Analysis (SC 2021) for software, GVK Industries (SC 2015) for FTS retrospectivity, Director of IT v. Bharti Cellular (SC 2010) for human-element test; (4) produce TRC + Form 10F + No-PE declaration; (5) if all fails, Form 26A is unavailable (non-resident payee) — fallback is Section 273B reasonable cause.
TDS Notice Reply near St Thomas Mount:

Across St Thomas Mount we look after firms on Thillaiganga Nagar Subway, 2nd Main Road, Ashok Path, Balusamy Street and College Road as well as the Krishnasamy Street, Lake View Road, Grand Southern Trunk Road and Inner Ring Road (Southern Sector) corridors — local TDS Notice Reply without the cross-city travel.

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