CPC has sent me an intimation under section 200A with a late fee on it. What does section 200A actually let them compute, when did the fee limb go in, and can I appeal it?
Section 200A is the machinery for processing a quarterly TDS statement under the Income-tax Act, 1961. Sub-section (1) runs (a) to (f): correct arithmetical errors and incorrect claims apparent from the statement, compute interest, compute the fee under section 234E, determine the sum payable or the refund, send an intimation, and grant the refund. The fee limb is clause (c), and the old clauses (c), (d) and (e) became (d), (e) and (f) when section 52 of the Finance Act, 2015 substituted clauses (c) to (f) for clauses (c) to (e) with effect from 1 June 2015 — so a submission that still calls the intimation clause (d) or the refund clause (e) is describing the law before that date. Under the 1961 Act the intimation cannot be sent after one year from the end of the financial year in which the statement is filed, and that limit sits in the proviso to sub-section (1), not in sub-section (2); under the successor provision, section 399 of the Income-tax Act, 2025, the same one-year limit is sub-section (2) itself. The intimation is deemed a notice of demand under the proviso to section 156, is appealable to the Commissioner (Appeals) under section 246A(1)(a), and can be rectified under section 154(1)(c). Whether a section 234E fee can be charged in a section 200A intimation for a quarter before 1 June 2015 is the point on which the High Courts have split — Karnataka and Kerala for the deductor, Gujarat, Rajasthan and Madras for the Revenue — and which High Court you are in decides it.
Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2025-04-01, reported as Section 200A of the Income-tax Act, 1961, as amended up to 2026. It bears on section 200A, section 234E, section 200(3), section 246A, section 154, section 156, section 201, section 206CB, section Rule 31A, section 399 (Act of 2025), section 427 (Act of 2025), section 357 (Act of 2025), section 397 (Act of 2025) of the Income Tax Act 1961, in TDS Defaults, Penalty and Assessment & Scrutiny matters.
The date decides the money. Every quarter from 1 July 2012 to 31 May 2015 is a quarter in which section 234E was in force but section 200A(1) had no fee limb, and CPC nevertheless issued intimations charging the fee for those quarters — often years later, and often revived when a deductor files a correction statement or the demand surfaces on the TRACES portal. Whether that fee survives depends entirely on which High Court's writ jurisdiction you are in. In Karnataka and Kerala it does not; in Gujarat, Tamil Nadu and wherever the Gujarat reasoning is followed, it does. The Tribunal will apply its own jurisdictional High Court, as the Bangalore Bench did in Kooud Software, so the same facts produce opposite results in Bengaluru and Chennai. There is no Supreme Court decision closing the question. For everything after 1 June 2015 the fight is not about the fee's validity but about the machinery. The fee is capped at the tax deductible for the quarter, so a nil or near-nil quarter carries a near-nil fee however long the delay; the department's own illustration on its late-filing-fee page has 155 days of delay computing to Rs 31,000 and being cut to Rs 8,400 because that is the TDS of the quarter — 155 x 200 = 31,000, capped at 8,400. And the intimation is a deemed notice of demand, appealable under section 246A(1)(a) and rectifiable under section 154(1)(c), so a deductor who treats it as a portal entry rather than a demand loses both the appeal window that section 249(2) runs from the service of the notice of demand and, eventually, the four years under section 154(7).
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200A. Processing of statements of tax deducted at source and other statements. (1) Where a statement of tax deduction at source or a correction statement has been made by a person deducting any sum (hereafter referred to in this section as deductor) under section 200, such statement shall be processed in the following manner, namely:— (a) the sums deductible under this Chapter shall be computed after making the following adjustments, namely:— (i) any arithmetical error in the statement; or (ii) an incorrect claim, apparent from any information in the statement; (b) the interest, if any, shall be computed on the basis of the sums deductible as computed in the statement; (c) the fee, if any, shall be computed in accordance with the provisions of section 234E; (d) the sum payable by, or the amount of refund due to, the deductor shall be determined after adjustment of the amount computed under clause (b) and clause (c) against any amount paid under section 200 or section 201 or section 234E and any amount paid otherwise by way of tax or interest or fee; (e) an intimation shall be prepared or generated and sent to the deductor specifying the sum determined to be payable by, or the amount of refund due to, him under clause (d); and (f) the amount of refund due to the deductor in pursuance of the determination under clause (d) shall be granted to the deductor: Provided that no intimation under this sub-section shall be sent after the expiry of one year from the end of the financial year in which the statement is filed. Explanation.—For the purposes of this sub-section, "an incorrect claim apparent from any information in the statement" shall mean a claim, on the basis of an entry, in the statement— (i) of an item, which is inconsistent with another entry of the same or some other item in such statement; (ii) in respect of rate of deduction of tax at source, where such rate is not in accordance with the provisions of this Act. (2) For the purposes of processing of statements under sub-section (1), the Board may make a scheme for centralised processing of statements of tax deducted at source to expeditiously determine the tax payable by, or the refund due to, the deductor as required under the said sub-section. (3) The Board may make a scheme for processing of statements made by any other person, not being a deductor. [This is the section as it stood at the repeal of the Income-tax Act, 1961. The same text, clause for clause, appears on the three most recent published versions of the section.] The related provisions: Section 234E(1): "Without prejudice to the provisions of the Act, where a person fails to deliver or cause to be delivered a statement within the time prescribed in sub-section (3) of section 200 or the proviso to sub-section (3) of section 206C, he shall be liable to pay, by way of fee, a sum of two hundred rupees for every day during which the failure continues." Sub-section (2): "The amount of fee referred to in sub-section (1) shall not exceed the amount of tax deductible or collectible, as the case may be." Sub-section (3): "The amount of fee referred to in sub-section (1) shall be paid before delivering or causing to be delivered a statement in accordance with sub-section (3) of section 200 or the proviso to sub-section (3) of section 206C." Sub-section (4): "The provisions of this section shall apply to a statement referred to in sub-section (3) of section 200 or the proviso to sub-section (3) of section 206C which is to be delivered or caused to be delivered for tax deducted at source or tax collected at source, as the case may be, on or after the 1st day of July, 2012." Proviso to section 156(1): "Provided that where any sum is determined to be payable by the assessee or the deductor or the collector under sub-section (1) of section 143 or sub-section (1) of section 200A or sub-section (1) of section 206CB, the intimation under those sub-sections shall be deemed to be a notice of demand for the purposes of this section." Section 246A(1) opening and clause (a): "Any assessee or any deductor or any collector aggrieved by any of the following orders (whether made before or after the appointed day) may appeal to the Commissioner (Appeals) against— (a) an order passed by a Joint Commissioner under clause (ii) of sub-section (3) of section 115VP or an order against the assessee where the assessee denies his liability to be assessed under this Act or an intimation under sub-section (1) or sub-section (1B) of section 143 or sub-section (1) of section 200A or sub-section (1) of section 206CB, where the assessee or the deductor or the collector objects to the making of adjustments, or any order of assessment under sub-section (3) of section 143 except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section (12) of section 144BA or section 144, to the income assessed, or to the amount of tax determined, or to the amount of loss computed, or to the status under which he is assessed". Clause (c) of the same sub-section: "an order made under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections except an order referred to in sub-section (12) of section 144BA". Section 154(1): "With a view to rectifying any mistake apparent from the record an income-tax authority referred to in section 116 may,— (a) amend any order passed by it under the provisions of this Act; (b) amend any intimation or deemed intimation under sub-section (1) of section 143; (c) amend any intimation under sub-section (1) of section 200A; (d) amend any intimation under sub-section (1) of section 206CB." Provisos to section 200(3): "Provided that the person may also deliver to the prescribed authority a correction statement for rectification of any mistake or to add, delete or update the information furnished in the statement delivered under this sub-section in such form and verified in such manner as may be specified by the authority: Provided further that no correction statement shall be delivered after the expiry of six years from the end of the financial year in which the statement referred to in sub-section (3) is required to be delivered."
Section 200A prescribes how the department processes a TDS statement and what it may put into the resulting intimation. It does not create a charge. Its own text was last changed on 1 April 2025; the Act that contains it was repealed with effect from 1 April 2026, and the last paragraph below sets out what still runs on it and what has replaced it. The position under section 200A is this. Sub-section (1) applies to a statement under section 200 and, since the Finance (No. 2) Act, 2014 (Act No. 25 of 2014) with effect from 1 October 2014, also to a correction statement. Six things happen, in order. Clause (a) recomputes the sums deductible after adjusting for an arithmetical error or for an incorrect claim apparent from any information in the statement, and the Explanation confines an "incorrect claim" to an entry inconsistent with another entry in the same statement, or a rate of deduction that is not in accordance with the Act. Clause (b) computes the interest. Clause (c) computes the fee, if any, in accordance with section 234E. Clause (d) determines the sum payable or the refund due, after setting the clause (b) and clause (c) amounts against anything already paid under section 200, section 201 or section 234E and anything otherwise paid as tax, interest or fee. Clause (e) prepares or generates the intimation and sends it to the deductor. Clause (f) grants the refund. The clause lettering matters, and it changed. Until 31 May 2015 sub-section (1) ran (a) to (e), with no fee limb: (a) sums deductible, (b) interest, (c) sum payable or refund, (d) intimation, (e) grant of refund. The footnote on the version published for 2015 reads "Clauses (c) to (f) shall be substituted for clauses (c) to (e) by the Finance Act, 2015, w.e.f. 1-6-2015", and the footnote on the version published for 2016 reads "Clauses (c) to (f) Sub. for clauses (c) to (e) by Act No. 20 of 2015 (w.e.f. 1-6-2015)." Act No. 20 of 2015 is the Finance Act, 2015, and section 52 of that Act, assented to on 14 May 2015, says it in terms: "In section 200A of the Income-tax Act, in sub-section (1), for clauses (c) to (e), the following clauses shall be substituted with effect from the 1st day of June, 2015, namely:—", the first of the substituted clauses being "(c) the fee, if any, shall be computed in accordance with the provisions of section 234E;". So the section 234E fee limb entered section 200A(1) as clause (c) on 1 June 2015, and everything from the determination of the sum payable onwards shifted one letter down. A reference to "the intimation under section 200A(1)(d)" or "the refund under section 200A(1)(e)" is a reference to the law as it stood before 1 June 2015. The time limit is in the proviso to sub-section (1), not in sub-section (2). It reads: no intimation under this sub-section shall be sent after the expiry of one year from the end of the financial year in which the statement is filed. That proviso has stood in the same words in every published version of the section from 2010 onwards and has not been amended since section 200A took effect on 1 April 2010. Sub-section (2) is not a time limit at all — it is the Board's power to make a scheme for centralised processing, and it is unamended since 2010. Sub-section (3), inserted by the Finance (No. 2) Act, 2024 (Act No. 15 of 2024) with effect from 1 April 2025, gives the Board a further power to make a scheme for processing statements made by a person who is not a deductor; the same Act added the words "and other statements" to the marginal note. That 1 April 2025 change is the most recent amendment, and is why the current text is dated from that day. Section 234E, inserted by the Finance Act, 2012 with effect from 1 July 2012, is the charge. It fixes a fee of two hundred rupees for every day the failure to deliver the statement continues; sub-section (2) caps the fee at the amount of tax deductible or collectible; sub-section (3) requires the fee to be paid before the statement is delivered; sub-section (4) applies the section to statements to be delivered on or after 1 July 2012. It is a fee, not a penalty: the Bombay High Court in Rashmikant Kundalia v. Union of India (Writ Petition No. 771 of 2014, 9 February 2015, Mohit S. Shah C.J. and B.P. Colabawalla J.) dismissed the challenge to it and held it is not punitive but a fee, and that a separate penalty provision, section 271H, exists alongside it. That judgment is under appeal: the Supreme Court granted leave against it on 3 January 2017 and the appeal was still being listed in September 2024, so nothing has reversed it but its validity is not finally closed. The rate and the cap have not changed: the section as it now stands still reads "two hundred rupees" and still caps the fee at the tax deductible or collectible, and carries no footnote recording any change. The intimation is not a soft document. Under the proviso to section 156(1) an intimation under section 200A(1) determining a sum payable is deemed to be a notice of demand. It is appealable: section 246A(1)(a) lets any assessee or any deductor or any collector appeal to the Commissioner (Appeals) against an intimation under sub-section (1) of section 200A where the deductor objects to the making of adjustments. That right is older than the fee limb — the words "section 143 or sub-section (1) of section 200A, where the assessee or the deductor objects" were substituted for "section 143, where the assessee objects" by the Finance Act, 2012 with effect from 1 July 2012, the same day section 234E came into force, and the Finance Act, 2015 then widened the same clause to take in section 206CB and the collector with effect from 1 June 2015. Rectification also lies: section 154(1)(c) expressly empowers an income-tax authority to amend any intimation under sub-section (1) of section 200A, and a section 154 order enhancing the assessment, reducing a refund or refusing the claim is itself appealable under section 246A(1)(c). An intimation under section 200A is not an order under section 201. The Delhi High Court in Vodafone Idea Ltd v. ACIT (W.P.(C) 2729/2026 and connected petitions, 18 August 2026) held that sections 200A and 201 operate on entirely different fields and spheres, and that once an order under section 201, or an appellate order arising from it, finds an amount refundable, that is a vested and crystallised right which cannot be withheld except by an order actually passed under section 245. The route to fix a statement, as opposed to fixing the intimation, is the correction statement under the first proviso to section 200(3), read with rule 31A. Rule 31A(2) as substituted by the Income-tax (Eleventh Amendment) Rules, 2016 with effect from 1 June 2016 fixes the quarterly due dates at 31 July, 31 October, 31 January and, for the quarter ending 31 March, 31 May of the following financial year, uniformly — the earlier separate, later date for Government offices, which the Gujarat High Court upheld against an Article 14 challenge in Rajesh Kourani, is no longer in the rule. The second proviso to section 200(3), inserted by the Finance (No. 2) Act, 2024 with effect from 1 April 2025, now bars a correction statement delivered after six years from the end of the financial year in which the original statement was due. The live dispute is whether a section 234E fee can be charged in a section 200A intimation for a period before 1 June 2015, when section 200A(1) carried no fee limb. The High Courts are divided and there is no Supreme Court decision resolving it. On the deductor's side: the Karnataka High Court in Fatheraj Singhvi v. Union of India (2016) held that because the amendment to section 200A took effect on 1 June 2015 and is prospective, no computation of the fee could be made in an intimation for an earlier period. The Kerala High Court has taken the same view — in Sajeev Mathew and Company v. ITO (TDS), Kochi (W.P.(C) No.24533 of 2021, Bechu Kurian Thomas J, 30 November 2021), following its own earlier decision in Sarala Memorial Hospital v. Union of India, the Court recorded that "it was held that the amendment would take effect only with effect from 1st June, 2015 and is thus prospective in nature", and ordered: "Accordingly, I quash Ext.P1 notice to the extent it demands fee under section 234E for the period from 2011-12 till 01.06.2015." The Bangalore Bench of the Tribunal applied Fatheraj Singhvi in Kooud Software P Ltd v. DDIT (CPC) — TDS (ITA Nos.82 to 90/Bang/2022, 25 March 2022) and deleted the pre-June-2015 levies, on the footing that it is bound by its jurisdictional High Court. On the Revenue's side: the Gujarat High Court in Rajesh Kourani v. Union of India (Special Civil Application No. 302 of 2014, Akil Kureshi and Biren Vaishnav JJ, 20 June 2017) dismissed the petition, holding at paragraph 19 that "section 200A of the Act is a machinery provision... On the other hand, section 234E is a charging provision creating a charge for levying fee for certain defaults in filing the statements. Under no circumstances a machinery provision can override or overrule a charging provision", and at paragraph 20 that "Even in absence of section 200A of the Act with introduction of section 234E, it was always open for the Revenue to demand and collect the fee for late filing of the statements. Section 200A would merely regulate the manner in which the computation of such fee would be made and demand raised." The Rajasthan High Court had already gone the same way two years earlier, in M/s Dundlod Shikshan Sansthan v. Union of India (D.B. Civil Writ Petition No. 8672/2014, Sunil Ambwani CJ and Veerendr Singh Siradhana J, 28 July 2015), which dealt with the point squarely and not merely as a question of vires: "In the present case, the fee was levied under section 200 for late filing of the returns, prior to the amendments made by the Finance Act, 2015 with effect from 1.6.2015 in Sections 200A, 246A and 272A providing for computation and appeal. We do not find that even prior to these amendments the imposition of fee was illegal." The writ petition was dismissed as having no merit, and the Jaipur Bench of the Tribunal has since followed it as binding in Shri Jagdish Prasad Bugalia v. ITO (TDS)-3 (ITA No. 704/JP/2017, 15 February 2018). The Madras High Court in Conceria International P Ltd v. ITO (W.P. No.16934 of 2021, Mohammed Shaffiq J, 10 November 2023) agreed with Gujarat and Rajasthan, relying on section 234E(1) as the substantive provision, section 234E(3) as providing for self-assessment and payment of the fee before the statement is delivered, and section 234E(4) as fixing 1 July 2012 as the operative date, and said in terms: "With due respect I am unable to subscribe to the view expressed by the Karnataka High Court in view of the reasons stated supra." The petition was dismissed and the challenge to the levy of late fee prior to 1 June 2015 was rejected. Rashmikant Kundalia is not authority on this split. It decided that section 234E is constitutionally valid; it did not decide whether the fee could be collected through a section 200A intimation before 1 June 2015. In Rajesh Kourani the petitioner's counsel expressly abandoned the constitutional challenge because of Rashmikant Kundalia and argued only the machinery point. How long this text governs. Section 536(1) of the Income-tax Act, 2025 provides that "The Income-tax Act, 1961 (43 of 1961) is hereby repealed", with effect from 1 April 2026. Section 536(2) saves what was done under it: nothing affects the previous operation of the repealed Act, or any right, privilege, obligation or liability acquired, accrued or incurred under it, and the provisions of the repealed Act continue to apply to any proceeding pending at commencement and to proceedings initiated on or after 1 April 2026, including notices, rectification, penalty and appeals. So everything above still governs a statement for any quarter up to and including the quarter ended 31 March 2026, and the intimation, rectification and appeal that follow from it, however late they come. The Board's transition FAQ puts the fence where the statement is filed rather than where the intimation lands: the statement for Q4 of FY 2025-26 (January to March 2026) is filed under the 1961 Act in Forms 24Q, 26Q, 27Q and 27EQ by 31 May 2026, while the statement for Q1 of tax year 2026-27 (April to June 2026) is filed under the 2025 Act in the new forms by 31 July 2026 and Q2 by 31 October 2026. For an obligation rather than a statement, the FAQ's rule is that the Act governing the deduction is fixed by the earlier of credit or payment — on or before 31 March 2026 the 1961 Act, on or after 1 April 2026 the 2025 Act. Under the 2025 Act the successor to section 200A is section 399, "Processing". The clause lettering survives intact: sub-section (1) runs (a) to (f), with the fee at clause (c) — "the fee, if any, shall be computed as per the provisions of section 427(1) and (2)" — the determination at (d), the intimation at (e) and the grant of the refund at (f). Two things move. The one-year limit is no longer in a proviso to sub-section (1): section 399(2) reads "The intimation under this section shall be sent within one year from the end of the tax year in which the statement is filed", and the Board's scheme power drops to sub-section (3). And section 399(1) is written to cover statements of tax collected at source as well as tax deducted at source, which section 200A did not. The fee itself is section 427: Rs 200 for every day the failure continues, not exceeding the amount of tax deductible or collectible, and payable before the statement is delivered — the same rate and the same cap. The appeal survives in the same terms: section 357(c) makes appealable before the Commissioner (Appeals) "an order being an intimation under section 270(1) or 399(1), where the assessee or the deductor or the collector objects to the adjustments made therein", and section 356(a) carries the identical entry for the Joint Commissioner (Appeals). The correction statement moves to section 397(3)(f), and the window there is two years, not six.
Not applicable — this is a statement of the statutory text as printed on the departmental section pages, with the amendment history taken from the footnote apparatus on those pages. No judicial reasoning is involved.
the fee, if any, shall be computed in accordance with the provisions of section 234E
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Handle my notice → Ask a CA on WhatsAppSection 200A is the machinery for processing a quarterly TDS statement under the Income-tax Act, 1961. Sub-section (1) runs (a) to (f): correct arithmetical errors and incorrect claims apparent from the statement, compute interest, compute the fee under section 234E, determine the sum payable or the refund, send an intimation, and grant the refund. The fee limb is clause (c), and the old clauses (c), (d) and (e) became (d), (e) and (f) when section 52 of the Finance Act, 2015 substituted clauses (c) to (f) for clauses (c) to (e) with effect from 1 June 2015 — so a submission that still calls the intimation clause (d) or the refund clause (e) is describing the law before that date. Under the 1961 Act the intimation cannot be sent after one year from the end of the financial year in which the statement is filed, and that limit sits in the proviso to sub-section (1), not in sub-section (2); under the successor provision, section 399 of the Income-tax Act, 2025, the same one-year limit is sub-section (2) itself. The intimation is deemed a notice of demand under the proviso to section 156, is appealable to the Commissioner (Appeals) under section 246A(1)(a), and can be rectified under section 154(1)(c). Whether a section 234E fee can be charged in a section 200A intimation for a quarter before 1 June 2015 is the point on which the High Courts have split — Karnataka and Kerala for the deductor, Gujarat, Rajasthan and Madras for the Revenue — and which High Court you are in decides it. This was decided by the CBDT Circulars & Instructions (Not applicable — statutory text) and bears on section 200A, section 234E, section 200(3), section 246A, section 154, section 156, section 201, section 206CB, section Rule 31A, section 399 (Act of 2025), section 427 (Act of 2025), section 357 (Act of 2025), section 397 (Act of 2025) of the Income Tax Act 1961. It is reported as Section 200A of the Income-tax Act, 1961, as amended up to 2026. The date decides the money. Every quarter from 1 July 2012 to 31 May 2015 is a quarter in which section 234E was in force but section 200A(1) had no fee limb, and CPC nevertheless issued intimations charging the fee for those quarters — often years later, and often revived when a deductor files a correction statement or the demand surfaces on the TRACES portal. Whether that fee survives depends entirely on which High Court's writ jurisdiction you are in. In Karnataka and Kerala it does not; in Gujarat, Tamil Nadu and wherever the Gujarat reasoning is followed, it does. The Tribunal will apply its own jurisdictional High Court, as the Bangalore Bench did in Kooud Software, so the same facts produce opposite results in Bengaluru and Chennai. There is no Supreme Court decision closing the question. For everything after 1 June 2015 the fight is not about the fee's validity but about the machinery. The fee is capped at the tax deductible for the quarter, so a nil or near-nil quarter carries a near-nil fee however long the delay; the department's own illustration on its late-filing-fee page has 155 days of delay computing to Rs 31,000 and being cut to Rs 8,400 because that is the TDS of the quarter — 155 x 200 = 31,000, capped at 8,400. And the intimation is a deemed notice of demand, appealable under section 246A(1)(a) and rectifiable under section 154(1)(c), so a deductor who treats it as a portal entry rather than a demand loses both the appeal window that section 249(2) runs from the service of the notice of demand and, eventually, the four years under section 154(7). If it applies to you, the first step is this: Read the intimation for the quarter it covers before anything else. If the quarter ended on or before 31 May 2015, the pre-1-June-2015 point is open and you should take it; if it ended after, it is not.
200A. Processing of statements of tax deducted at source and other statements. (1) Where a statement of tax deduction at source or a correction statement has been made by a person deducting any sum (hereafter referred to in this section as deductor) under section 200, such statement shall be processed in the following manner, namely:— (a) the sums deductible under this Chapter shall be computed after making the following adjustments, namely:— (i) any arithmetical error in the statement; or (ii) an incorrect claim, apparent from any information in the statement; (b) the interest, if any, shall be computed on the basis of the sums deductible as computed in the statement; (c) the fee, if any, shall be computed in accordance with the provisions of section 234E; (d) the sum payable by, or the amount of refund due to, the deductor shall be determined after adjustment of the amount computed under clause (b) and clause (c) against any amount paid under section 200 or section 201 or section 234E and any amount paid otherwise by way of tax or interest or fee; (e) an intimation shall be prepared or generated and sent to the deductor specifying the sum determined to be payable by, or the amount of refund due to, him under clause (d); and (f) the amount of refund due to the deductor in pursuance of the determination under clause (d) shall be granted to the deductor: Provided that no intimation under this sub-section shall be sent after the expiry of one year from the end of the financial year in which the statement is filed. Explanation.—For the purposes of this sub-section, "an incorrect claim apparent from any information in the statement" shall mean a claim, on the basis of an entry, in the statement— (i) of an item, which is inconsistent with another entry of the same or some other item in such statement; (ii) in respect of rate of deduction of tax at source, where such rate is not in accordance with the provisions of this Act. (2) For the purposes of processing of statements under sub-section (1), the Board may make a scheme for centralised processing of statements of tax deducted at source to expeditiously determine the tax payable by, or the refund due to, the deductor as required under the said sub-section. (3) The Board may make a scheme for processing of statements made by any other person, not being a deductor. [This is the section as it stood at the repeal of the Income-tax Act, 1961. The same text, clause for clause, appears on the three most recent published versions of the section.] The related provisions: Section 234E(1): "Without prejudice to the provisions of the Act, where a person fails to deliver or cause to be delivered a statement within the time prescribed in sub-section (3) of section 200 or the proviso to sub-section (3) of section 206C, he shall be liable to pay, by way of fee, a sum of two hundred rupees for every day during which the failure continues." Sub-section (2): "The amount of fee referred to in sub-section (1) shall not exceed the amount of tax deductible or collectible, as the case may be." Sub-section (3): "The amount of fee referred to in sub-section (1) shall be paid before delivering or causing to be delivered a statement in accordance with sub-section (3) of section 200 or the proviso to sub-section (3) of section 206C." Sub-section (4): "The provisions of this section shall apply to a statement referred to in sub-section (3) of section 200 or the proviso to sub-section (3) of section 206C which is to be delivered or caused to be delivered for tax deducted at source or tax collected at source, as the case may be, on or after the 1st day of July, 2012." Proviso to section 156(1): "Provided that where any sum is determined to be payable by the assessee or the deductor or the collector under sub-section (1) of section 143 or sub-section (1) of section 200A or sub-section (1) of section 206CB, the intimation under those sub-sections shall be deemed to be a notice of demand for the purposes of this section." Section 246A(1) opening and clause (a): "Any assessee or any deductor or any collector aggrieved by any of the following orders (whether made before or after the appointed day) may appeal to the Commissioner (Appeals) against— (a) an order passed by a Joint Commissioner under clause (ii) of sub-section (3) of section 115VP or an order against the assessee where the assessee denies his liability to be assessed under this Act or an intimation under sub-section (1) or sub-section (1B) of section 143 or sub-section (1) of section 200A or sub-section (1) of section 206CB, where the assessee or the deductor or the collector objects to the making of adjustments, or any order of assessment under sub-section (3) of section 143 except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section (12) of section 144BA or section 144, to the income assessed, or to the amount of tax determined, or to the amount of loss computed, or to the status under which he is assessed". Clause (c) of the same sub-section: "an order made under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections except an order referred to in sub-section (12) of section 144BA". Section 154(1): "With a view to rectifying any mistake apparent from the record an income-tax authority referred to in section 116 may,— (a) amend any order passed by it under the provisions of this Act; (b) amend any intimation or deemed intimation under sub-section (1) of section 143; (c) amend any intimation under sub-section (1) of section 200A; (d) amend any intimation under sub-section (1) of section 206CB." Provisos to section 200(3): "Provided that the person may also deliver to the prescribed authority a correction statement for rectification of any mistake or to add, delete or update the information furnished in the statement delivered under this sub-section in such form and verified in such manner as may be specified by the authority: Provided further that no correction statement shall be delivered after the expiry of six years from the end of the financial year in which the statement referred to in sub-section (3) is required to be delivered." The matter was decided on 2025-04-01 by the CBDT Circulars & Instructions (Not applicable — statutory text). On those facts the CBDT Circulars & Instructions held as follows. Section 200A prescribes how the department processes a TDS statement and what it may put into the resulting intimation. It does not create a charge. Its own text was last changed on 1 April 2025; the Act that contains it was repealed with effect from 1 April 2026, and the last paragraph below sets out what still runs on it and what has replaced it. The position under section 200A is this. Sub-section (1) applies to a statement under section 200 and, since the Finance (No. 2) Act, 2014 (Act No. 25 of 2014) with effect from 1 October 2014, also to a correction statement. Six things happen, in order. Clause (a) recomputes the sums deductible after adjusting for an arithmetical error or for an incorrect claim apparent from any information in the statement, and the Explanation confines an "incorrect claim" to an entry inconsistent with another entry in the same statement, or a rate of deduction that is not in accordance with the Act. Clause (b) computes the interest. Clause (c) computes the fee, if any, in accordance with section 234E. Clause (d) determines the sum payable or the refund due, after setting the clause (b) and clause (c) amounts against anything already paid under section 200, section 201 or section 234E and anything otherwise paid as tax, interest or fee. Clause (e) prepares or generates the intimation and sends it to the deductor. Clause (f) grants the refund. The clause lettering matters, and it changed. Until 31 May 2015 sub-section (1) ran (a) to (e), with no fee limb: (a) sums deductible, (b) interest, (c) sum payable or refund, (d) intimation, (e) grant of refund. The footnote on the version published for 2015 reads "Clauses (c) to (f) shall be substituted for clauses (c) to (e) by the Finance Act, 2015, w.e.f. 1-6-2015", and the footnote on the version published for 2016 reads "Clauses (c) to (f) Sub. for clauses (c) to (e) by Act No. 20 of 2015 (w.e.f. 1-6-2015)." Act No. 20 of 2015 is the Finance Act, 2015, and section 52 of that Act, assented to on 14 May 2015, says it in terms: "In section 200A of the Income-tax Act, in sub-section (1), for clauses (c) to (e), the following clauses shall be substituted with effect from the 1st day of June, 2015, namely:—", the first of the substituted clauses being "(c) the fee, if any, shall be computed in accordance with the provisions of section 234E;". So the section 234E fee limb entered section 200A(1) as clause (c) on 1 June 2015, and everything from the determination of the sum payable onwards shifted one letter down. A reference to "the intimation under section 200A(1)(d)" or "the refund under section 200A(1)(e)" is a reference to the law as it stood before 1 June 2015. The time limit is in the proviso to sub-section (1), not in sub-section (2). It reads: no intimation under this sub-section shall be sent after the expiry of one year from the end of the financial year in which the statement is filed. That proviso has stood in the same words in every published version of the section from 2010 onwards and has not been amended since section 200A took effect on 1 April 2010. Sub-section (2) is not a time limit at all — it is the Board's power to make a scheme for centralised processing, and it is unamended since 2010. Sub-section (3), inserted by the Finance (No. 2) Act, 2024 (Act No. 15 of 2024) with effect from 1 April 2025, gives the Board a further power to make a scheme for processing statements made by a person who is not a deductor; the same Act added the words "and other statements" to the marginal note. That 1 April 2025 change is the most recent amendment, and is why the current text is dated from that day. Section 234E, inserted by the Finance Act, 2012 with effect from 1 July 2012, is the charge. It fixes a fee of two hundred rupees for every day the failure to deliver the statement continues; sub-section (2) caps the fee at the amount of tax deductible or collectible; sub-section (3) requires the fee to be paid before the statement is delivered; sub-section (4) applies the section to statements to be delivered on or after 1 July 2012. It is a fee, not a penalty: the Bombay High Court in Rashmikant Kundalia v. Union of India (Writ Petition No. 771 of 2014, 9 February 2015, Mohit S. Shah C.J. and B.P. Colabawalla J.) dismissed the challenge to it and held it is not punitive but a fee, and that a separate penalty provision, section 271H, exists alongside it. That judgment is under appeal: the Supreme Court granted leave against it on 3 January 2017 and the appeal was still being listed in September 2024, so nothing has reversed it but its validity is not finally closed. The rate and the cap have not changed: the section as it now stands still reads "two hundred rupees" and still caps the fee at the tax deductible or collectible, and carries no footnote recording any change. The intimation is not a soft document. Under the proviso to section 156(1) an intimation under section 200A(1) determining a sum payable is deemed to be a notice of demand. It is appealable: section 246A(1)(a) lets any assessee or any deductor or any collector appeal to the Commissioner (Appeals) against an intimation under sub-section (1) of section 200A where the deductor objects to the making of adjustments. That right is older than the fee limb — the words "section 143 or sub-section (1) of section 200A, where the assessee or the deductor objects" were substituted for "section 143, where the assessee objects" by the Finance Act, 2012 with effect from 1 July 2012, the same day section 234E came into force, and the Finance Act, 2015 then widened the same clause to take in section 206CB and the collector with effect from 1 June 2015. Rectification also lies: section 154(1)(c) expressly empowers an income-tax authority to amend any intimation under sub-section (1) of section 200A, and a section 154 order enhancing the assessment, reducing a refund or refusing the claim is itself appealable under section 246A(1)(c). An intimation under section 200A is not an order under section 201. The Delhi High Court in Vodafone Idea Ltd v. ACIT (W.P.(C) 2729/2026 and connected petitions, 18 August 2026) held that sections 200A and 201 operate on entirely different fields and spheres, and that once an order under section 201, or an appellate order arising from it, finds an amount refundable, that is a vested and crystallised right which cannot be withheld except by an order actually passed under section 245. The route to fix a statement, as opposed to fixing the intimation, is the correction statement under the first proviso to section 200(3), read with rule 31A. Rule 31A(2) as substituted by the Income-tax (Eleventh Amendment) Rules, 2016 with effect from 1 June 2016 fixes the quarterly due dates at 31 July, 31 October, 31 January and, for the quarter ending 31 March, 31 May of the following financial year, uniformly — the earlier separate, later date for Government offices, which the Gujarat High Court upheld against an Article 14 challenge in Rajesh Kourani, is no longer in the rule. The second proviso to section 200(3), inserted by the Finance (No. 2) Act, 2024 with effect from 1 April 2025, now bars a correction statement delivered after six years from the end of the financial year in which the original statement was due. The live dispute is whether a section 234E fee can be charged in a section 200A intimation for a period before 1 June 2015, when section 200A(1) carried no fee limb. The High Courts are divided and there is no Supreme Court decision resolving it. On the deductor's side: the Karnataka High Court in Fatheraj Singhvi v. Union of India (2016) held that because the amendment to section 200A took effect on 1 June 2015 and is prospective, no computation of the fee could be made in an intimation for an earlier period. The Kerala High Court has taken the same view — in Sajeev Mathew and Company v. ITO (TDS), Kochi (W.P.(C) No.24533 of 2021, Bechu Kurian Thomas J, 30 November 2021), following its own earlier decision in Sarala Memorial Hospital v. Union of India, the Court recorded that "it was held that the amendment would take effect only with effect from 1st June, 2015 and is thus prospective in nature", and ordered: "Accordingly, I quash Ext.P1 notice to the extent it demands fee under section 234E for the period from 2011-12 till 01.06.2015." The Bangalore Bench of the Tribunal applied Fatheraj Singhvi in Kooud Software P Ltd v. DDIT (CPC) — TDS (ITA Nos.82 to 90/Bang/2022, 25 March 2022) and deleted the pre-June-2015 levies, on the footing that it is bound by its jurisdictional High Court. On the Revenue's side: the Gujarat High Court in Rajesh Kourani v. Union of India (Special Civil Application No. 302 of 2014, Akil Kureshi and Biren Vaishnav JJ, 20 June 2017) dismissed the petition, holding at paragraph 19 that "section 200A of the Act is a machinery provision... On the other hand, section 234E is a charging provision creating a charge for levying fee for certain defaults in filing the statements. Under no circumstances a machinery provision can override or overrule a charging provision", and at paragraph 20 that "Even in absence of section 200A of the Act with introduction of section 234E, it was always open for the Revenue to demand and collect the fee for late filing of the statements. Section 200A would merely regulate the manner in which the computation of such fee would be made and demand raised." The Rajasthan High Court had already gone the same way two years earlier, in M/s Dundlod Shikshan Sansthan v. Union of India (D.B. Civil Writ Petition No. 8672/2014, Sunil Ambwani CJ and Veerendr Singh Siradhana J, 28 July 2015), which dealt with the point squarely and not merely as a question of vires: "In the present case, the fee was levied under section 200 for late filing of the returns, prior to the amendments made by the Finance Act, 2015 with effect from 1.6.2015 in Sections 200A, 246A and 272A providing for computation and appeal. We do not find that even prior to these amendments the imposition of fee was illegal." The writ petition was dismissed as having no merit, and the Jaipur Bench of the Tribunal has since followed it as binding in Shri Jagdish Prasad Bugalia v. ITO (TDS)-3 (ITA No. 704/JP/2017, 15 February 2018). The Madras High Court in Conceria International P Ltd v. ITO (W.P. No.16934 of 2021, Mohammed Shaffiq J, 10 November 2023) agreed with Gujarat and Rajasthan, relying on section 234E(1) as the substantive provision, section 234E(3) as providing for self-assessment and payment of the fee before the statement is delivered, and section 234E(4) as fixing 1 July 2012 as the operative date, and said in terms: "With due respect I am unable to subscribe to the view expressed by the Karnataka High Court in view of the reasons stated supra." The petition was dismissed and the challenge to the levy of late fee prior to 1 June 2015 was rejected. Rashmikant Kundalia is not authority on this split. It decided that section 234E is constitutionally valid; it did not decide whether the fee could be collected through a section 200A intimation before 1 June 2015. In Rajesh Kourani the petitioner's counsel expressly abandoned the constitutional challenge because of Rashmikant Kundalia and argued only the machinery point. How long this text governs. Section 536(1) of the Income-tax Act, 2025 provides that "The Income-tax Act, 1961 (43 of 1961) is hereby repealed", with effect from 1 April 2026. Section 536(2) saves what was done under it: nothing affects the previous operation of the repealed Act, or any right, privilege, obligation or liability acquired, accrued or incurred under it, and the provisions of the repealed Act continue to apply to any proceeding pending at commencement and to proceedings initiated on or after 1 April 2026, including notices, rectification, penalty and appeals. So everything above still governs a statement for any quarter up to and including the quarter ended 31 March 2026, and the intimation, rectification and appeal that follow from it, however late they come. The Board's transition FAQ puts the fence where the statement is filed rather than where the intimation lands: the statement for Q4 of FY 2025-26 (January to March 2026) is filed under the 1961 Act in Forms 24Q, 26Q, 27Q and 27EQ by 31 May 2026, while the statement for Q1 of tax year 2026-27 (April to June 2026) is filed under the 2025 Act in the new forms by 31 July 2026 and Q2 by 31 October 2026. For an obligation rather than a statement, the FAQ's rule is that the Act governing the deduction is fixed by the earlier of credit or payment — on or before 31 March 2026 the 1961 Act, on or after 1 April 2026 the 2025 Act. Under the 2025 Act the successor to section 200A is section 399, "Processing". The clause lettering survives intact: sub-section (1) runs (a) to (f), with the fee at clause (c) — "the fee, if any, shall be computed as per the provisions of section 427(1) and (2)" — the determination at (d), the intimation at (e) and the grant of the refund at (f). Two things move. The one-year limit is no longer in a proviso to sub-section (1): section 399(2) reads "The intimation under this section shall be sent within one year from the end of the tax year in which the statement is filed", and the Board's scheme power drops to sub-section (3). And section 399(1) is written to cover statements of tax collected at source as well as tax deducted at source, which section 200A did not. The fee itself is section 427: Rs 200 for every day the failure continues, not exceeding the amount of tax deductible or collectible, and payable before the statement is delivered — the same rate and the same cap. The appeal survives in the same terms: section 357(c) makes appealable before the Commissioner (Appeals) "an order being an intimation under section 270(1) or 399(1), where the assessee or the deductor or the collector objects to the adjustments made therein", and section 356(a) carries the identical entry for the Joint Commissioner (Appeals). The correction statement moves to section 397(3)(f), and the window there is two years, not six.
Not applicable — this is a statement of the statutory text as printed on the departmental section pages, with the amendment history taken from the footnote apparatus on those pages. No judicial reasoning is involved. In the words reproduced by the source cited on this page: "the fee, if any, shall be computed in accordance with the provisions of section 234E"
It was decided by the CBDT Circulars & Instructions on 2025-04-01 and is reported as Section 200A of the Income-tax Act, 1961, as amended up to 2026. Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them. A CBDT circular or instruction binds officers of the department but not the assessee and not the courts. Where a circular helps you, you may hold the department to it. Where it hurts you, it cannot override the Act or a judgment. On section 200A, section 234E, section 200(3), section 246A, section 154, section 156, section 201, section 206CB, section Rule 31A, section 399 (Act of 2025), section 427 (Act of 2025), section 357 (Act of 2025), section 397 (Act of 2025), the practical question is whether the facts of your own notice match the facts of this case closely enough for the same rule to apply.
It cuts both ways and is cited by both sides. Section 200A prescribes how the department processes a TDS statement and what it may put into the resulting intimation. It does not create a charge. Its own text was last changed on 1 April 2025; the Act that contains it was repealed with effect from 1 April 2026, and the last paragraph below sets out what still runs on it and what has replaced it. The position under section 200A is this. Sub-section (1) applies to a statement under section 200 and, since the Finance (No. 2) Act, 2014 (Act No. 25 of 2014) with effect from 1 October 2014, also to a correction statement. Six things happen, in order. Clause (a) recomputes the sums deductible after adjusting for an arithmetical error or for an incorrect claim apparent from any information in the statement, and the Explanation confines an "incorrect claim" to an entry inconsistent with another entry in the same statement, or a rate of deduction that is not in accordance with the Act. Clause (b) computes the interest. Clause (c) computes the fee, if any, in accordance with section 234E. Clause (d) determines the sum payable or the refund due, after setting the clause (b) and clause (c) amounts against anything already paid under section 200, section 201 or section 234E and anything otherwise paid as tax, interest or fee. Clause (e) prepares or generates the intimation and sends it to the deductor. Clause (f) grants the refund. The clause lettering matters, and it changed. Until 31 May 2015 sub-section (1) ran (a) to (e), with no fee limb: (a) sums deductible, (b) interest, (c) sum payable or refund, (d) intimation, (e) grant of refund. The footnote on the version published for 2015 reads "Clauses (c) to (f) shall be substituted for clauses (c) to (e) by the Finance Act, 2015, w.e.f. 1-6-2015", and the footnote on the version published for 2016 reads "Clauses (c) to (f) Sub. for clauses (c) to (e) by Act No. 20 of 2015 (w.e.f. 1-6-2015)." Act No. 20 of 2015 is the Finance Act, 2015, and section 52 of that Act, assented to on 14 May 2015, says it in terms: "In section 200A of the Income-tax Act, in sub-section (1), for clauses (c) to (e), the following clauses shall be substituted with effect from the 1st day of June, 2015, namely:—", the first of the substituted clauses being "(c) the fee, if any, shall be computed in accordance with the provisions of section 234E;". So the section 234E fee limb entered section 200A(1) as clause (c) on 1 June 2015, and everything from the determination of the sum payable onwards shifted one letter down. A reference to "the intimation under section 200A(1)(d)" or "the refund under section 200A(1)(e)" is a reference to the law as it stood before 1 June 2015. The time limit is in the proviso to sub-section (1), not in sub-section (2). It reads: no intimation under this sub-section shall be sent after the expiry of one year from the end of the financial year in which the statement is filed. That proviso has stood in the same words in every published version of the section from 2010 onwards and has not been amended since section 200A took effect on 1 April 2010. Sub-section (2) is not a time limit at all — it is the Board's power to make a scheme for centralised processing, and it is unamended since 2010. Sub-section (3), inserted by the Finance (No. 2) Act, 2024 (Act No. 15 of 2024) with effect from 1 April 2025, gives the Board a further power to make a scheme for processing statements made by a person who is not a deductor; the same Act added the words "and other statements" to the marginal note. That 1 April 2025 change is the most recent amendment, and is why the current text is dated from that day. Section 234E, inserted by the Finance Act, 2012 with effect from 1 July 2012, is the charge. It fixes a fee of two hundred rupees for every day the failure to deliver the statement continues; sub-section (2) caps the fee at the amount of tax deductible or collectible; sub-section (3) requires the fee to be paid before the statement is delivered; sub-section (4) applies the section to statements to be delivered on or after 1 July 2012. It is a fee, not a penalty: the Bombay High Court in Rashmikant Kundalia v. Union of India (Writ Petition No. 771 of 2014, 9 February 2015, Mohit S. Shah C.J. and B.P. Colabawalla J.) dismissed the challenge to it and held it is not punitive but a fee, and that a separate penalty provision, section 271H, exists alongside it. That judgment is under appeal: the Supreme Court granted leave against it on 3 January 2017 and the appeal was still being listed in September 2024, so nothing has reversed it but its validity is not finally closed. The rate and the cap have not changed: the section as it now stands still reads "two hundred rupees" and still caps the fee at the tax deductible or collectible, and carries no footnote recording any change. The intimation is not a soft document. Under the proviso to section 156(1) an intimation under section 200A(1) determining a sum payable is deemed to be a notice of demand. It is appealable: section 246A(1)(a) lets any assessee or any deductor or any collector appeal to the Commissioner (Appeals) against an intimation under sub-section (1) of section 200A where the deductor objects to the making of adjustments. That right is older than the fee limb — the words "section 143 or sub-section (1) of section 200A, where the assessee or the deductor objects" were substituted for "section 143, where the assessee objects" by the Finance Act, 2012 with effect from 1 July 2012, the same day section 234E came into force, and the Finance Act, 2015 then widened the same clause to take in section 206CB and the collector with effect from 1 June 2015. Rectification also lies: section 154(1)(c) expressly empowers an income-tax authority to amend any intimation under sub-section (1) of section 200A, and a section 154 order enhancing the assessment, reducing a refund or refusing the claim is itself appealable under section 246A(1)(c). An intimation under section 200A is not an order under section 201. The Delhi High Court in Vodafone Idea Ltd v. ACIT (W.P.(C) 2729/2026 and connected petitions, 18 August 2026) held that sections 200A and 201 operate on entirely different fields and spheres, and that once an order under section 201, or an appellate order arising from it, finds an amount refundable, that is a vested and crystallised right which cannot be withheld except by an order actually passed under section 245. The route to fix a statement, as opposed to fixing the intimation, is the correction statement under the first proviso to section 200(3), read with rule 31A. Rule 31A(2) as substituted by the Income-tax (Eleventh Amendment) Rules, 2016 with effect from 1 June 2016 fixes the quarterly due dates at 31 July, 31 October, 31 January and, for the quarter ending 31 March, 31 May of the following financial year, uniformly — the earlier separate, later date for Government offices, which the Gujarat High Court upheld against an Article 14 challenge in Rajesh Kourani, is no longer in the rule. The second proviso to section 200(3), inserted by the Finance (No. 2) Act, 2024 with effect from 1 April 2025, now bars a correction statement delivered after six years from the end of the financial year in which the original statement was due. The live dispute is whether a section 234E fee can be charged in a section 200A intimation for a period before 1 June 2015, when section 200A(1) carried no fee limb. The High Courts are divided and there is no Supreme Court decision resolving it. On the deductor's side: the Karnataka High Court in Fatheraj Singhvi v. Union of India (2016) held that because the amendment to section 200A took effect on 1 June 2015 and is prospective, no computation of the fee could be made in an intimation for an earlier period. The Kerala High Court has taken the same view — in Sajeev Mathew and Company v. ITO (TDS), Kochi (W.P.(C) No.24533 of 2021, Bechu Kurian Thomas J, 30 November 2021), following its own earlier decision in Sarala Memorial Hospital v. Union of India, the Court recorded that "it was held that the amendment would take effect only with effect from 1st June, 2015 and is thus prospective in nature", and ordered: "Accordingly, I quash Ext.P1 notice to the extent it demands fee under section 234E for the period from 2011-12 till 01.06.2015." The Bangalore Bench of the Tribunal applied Fatheraj Singhvi in Kooud Software P Ltd v. DDIT (CPC) — TDS (ITA Nos.82 to 90/Bang/2022, 25 March 2022) and deleted the pre-June-2015 levies, on the footing that it is bound by its jurisdictional High Court. On the Revenue's side: the Gujarat High Court in Rajesh Kourani v. Union of India (Special Civil Application No. 302 of 2014, Akil Kureshi and Biren Vaishnav JJ, 20 June 2017) dismissed the petition, holding at paragraph 19 that "section 200A of the Act is a machinery provision... On the other hand, section 234E is a charging provision creating a charge for levying fee for certain defaults in filing the statements. Under no circumstances a machinery provision can override or overrule a charging provision", and at paragraph 20 that "Even in absence of section 200A of the Act with introduction of section 234E, it was always open for the Revenue to demand and collect the fee for late filing of the statements. Section 200A would merely regulate the manner in which the computation of such fee would be made and demand raised." The Rajasthan High Court had already gone the same way two years earlier, in M/s Dundlod Shikshan Sansthan v. Union of India (D.B. Civil Writ Petition No. 8672/2014, Sunil Ambwani CJ and Veerendr Singh Siradhana J, 28 July 2015), which dealt with the point squarely and not merely as a question of vires: "In the present case, the fee was levied under section 200 for late filing of the returns, prior to the amendments made by the Finance Act, 2015 with effect from 1.6.2015 in Sections 200A, 246A and 272A providing for computation and appeal. We do not find that even prior to these amendments the imposition of fee was illegal." The writ petition was dismissed as having no merit, and the Jaipur Bench of the Tribunal has since followed it as binding in Shri Jagdish Prasad Bugalia v. ITO (TDS)-3 (ITA No. 704/JP/2017, 15 February 2018). The Madras High Court in Conceria International P Ltd v. ITO (W.P. No.16934 of 2021, Mohammed Shaffiq J, 10 November 2023) agreed with Gujarat and Rajasthan, relying on section 234E(1) as the substantive provision, section 234E(3) as providing for self-assessment and payment of the fee before the statement is delivered, and section 234E(4) as fixing 1 July 2012 as the operative date, and said in terms: "With due respect I am unable to subscribe to the view expressed by the Karnataka High Court in view of the reasons stated supra." The petition was dismissed and the challenge to the levy of late fee prior to 1 June 2015 was rejected. Rashmikant Kundalia is not authority on this split. It decided that section 234E is constitutionally valid; it did not decide whether the fee could be collected through a section 200A intimation before 1 June 2015. In Rajesh Kourani the petitioner's counsel expressly abandoned the constitutional challenge because of Rashmikant Kundalia and argued only the machinery point. How long this text governs. Section 536(1) of the Income-tax Act, 2025 provides that "The Income-tax Act, 1961 (43 of 1961) is hereby repealed", with effect from 1 April 2026. Section 536(2) saves what was done under it: nothing affects the previous operation of the repealed Act, or any right, privilege, obligation or liability acquired, accrued or incurred under it, and the provisions of the repealed Act continue to apply to any proceeding pending at commencement and to proceedings initiated on or after 1 April 2026, including notices, rectification, penalty and appeals. So everything above still governs a statement for any quarter up to and including the quarter ended 31 March 2026, and the intimation, rectification and appeal that follow from it, however late they come. The Board's transition FAQ puts the fence where the statement is filed rather than where the intimation lands: the statement for Q4 of FY 2025-26 (January to March 2026) is filed under the 1961 Act in Forms 24Q, 26Q, 27Q and 27EQ by 31 May 2026, while the statement for Q1 of tax year 2026-27 (April to June 2026) is filed under the 2025 Act in the new forms by 31 July 2026 and Q2 by 31 October 2026. For an obligation rather than a statement, the FAQ's rule is that the Act governing the deduction is fixed by the earlier of credit or payment — on or before 31 March 2026 the 1961 Act, on or after 1 April 2026 the 2025 Act. Under the 2025 Act the successor to section 200A is section 399, "Processing". The clause lettering survives intact: sub-section (1) runs (a) to (f), with the fee at clause (c) — "the fee, if any, shall be computed as per the provisions of section 427(1) and (2)" — the determination at (d), the intimation at (e) and the grant of the refund at (f). Two things move. The one-year limit is no longer in a proviso to sub-section (1): section 399(2) reads "The intimation under this section shall be sent within one year from the end of the tax year in which the statement is filed", and the Board's scheme power drops to sub-section (3). And section 399(1) is written to cover statements of tax collected at source as well as tax deducted at source, which section 200A did not. The fee itself is section 427: Rs 200 for every day the failure continues, not exceeding the amount of tax deductible or collectible, and payable before the statement is delivered — the same rate and the same cap. The appeal survives in the same terms: section 357(c) makes appealable before the Commissioner (Appeals) "an order being an intimation under section 270(1) or 399(1), where the assessee or the deductor or the collector objects to the adjustments made therein", and section 356(a) carries the identical entry for the Joint Commissioner (Appeals). The correction statement moves to section 397(3)(f), and the window there is two years, not six. It arises in TDS Defaults, Penalty and Assessment & Scrutiny matters, on section 200A, section 234E, section 200(3), section 246A, section 154, section 156, section 201, section 206CB, section Rule 31A, section 399 (Act of 2025), section 427 (Act of 2025), section 357 (Act of 2025), section 397 (Act of 2025) of the Income Tax Act 1961, and was decided by Not applicable — statutory text. Before relying on it, read the source linked on this page and check whether it has since been distinguished, overruled or overtaken by an amendment to the Income Tax Act. In practice the steps that follow from it are these. Check which High Court's jurisdiction you are in, and say so in the appeal. Karnataka (Fatheraj Singhvi) and Kerala (Sarala Memorial Hospital, applied in Sajeev Mathew) are for the deductor; Gujarat (Rajesh Kourani), Rajasthan (Dundlod Shikshan Sansthan) and Madras (Conceria International) are against. The Tribunal is bound by the High Court above it — the Bangalore Bench followed Karnataka in Kooud Software, the Jaipur Bench followed Rajasthan in Jagdish Prasad Bugalia. Check the proviso to section 200A(1) on every intimation: it cannot be sent after one year from the end of the financial year in which the statement was filed. An intimation outside that window is bad on its face, whatever it charges. Check the clause lettering in anything you are served with or are about to file. After 1 June 2015 the fee is clause (c), the determination is clause (d), the intimation is clause (e) and the refund is clause (f). Do not cite clause (d) for the intimation unless the period is before that date. Recompute the fee yourself: two hundred rupees times the number of days from the day after the rule 31A(2) due date to the day the statement was actually filed, then cap it at the tax deductible for that quarter under section 234E(2). The cap is the point most demands get wrong in the deductor's favour and most deductors never check. Appeal the intimation to the Commissioner (Appeals) under section 246A(1)(a) — a deductor has that right in terms, and has had it since 1 July 2012. Do not accept that no appeal lies against a CPC intimation. Use section 154(1)(c) where the error is arithmetical or a wrong rate picked up by CPC, and keep the appeal alive in parallel; a section 154 order that enhances the demand or refuses the claim is itself appealable under section 246A(1)(c). Where the underlying statement is wrong, file a correction statement — and work out the window before you rely on it, because it is not the same under the two Acts. For a statement delivered under section 200 of the 1961 Act, the route is the first proviso to section 200(3) and the second proviso, inserted with effect from 1 April 2025, bars a correction statement after six years from the end of the financial year in which the original statement was due. For a statement under the 2025 Act, the route is section 397(3)(f) and the window is two years from the end of the tax year in which the statement was required to be delivered — so a Q1 tax-year-2026-27 statement can be corrected only until 31 March 2029. Section 397(3)(f) is written to reach statements required "under the said clauses or under section 200 of the Income-tax Act, 1961", while the Board's transition FAQ says corrections for FY 2025-26 and earlier go under the 1961 framework; until that overlap is resolved, work to the shorter window. Do not argue for waiver of the section 234E fee. There is no waiver machinery in section 234E, and Rashmikant Kundalia upheld the levy. The arguments that work are the period point, the one-year proviso, the cap and the arithmetic. For any statement from the quarter beginning 1 April 2026, stop citing section 200A and cite section 399 of the Income-tax Act, 2025 — same clause lettering, fee still at clause (c), but the one-year limit is now sub-section (2) and not a proviso to sub-section (1), and the Board's scheme power is sub-section (3). The fee is section 427, the appeal is section 357(c) before the Commissioner (Appeals) or section 356(a) before the Joint Commissioner (Appeals), and the correction statement is section 397(3)(f).
Superseded by amendment. The text above is section 200A of the Income-tax Act, 1961 as it stood at the repeal of that Act, identical clause for clause across the three most recent published versions of the section. The status is "superseded by amendment" because the 1961 Act stands repealed by section 536(1) of the Income-tax Act, 2025 from 1 April 2026; the savings in section 536(2) keep this section governing every statement up to the quarter ended 31 March 2026 and everything following from it, with section 399 governing thereafter. The 1 June 2015 change is corroborated four ways: the version published for 2015 carries the amendment in prospective form, the version for 2016 carries it in enacted form crediting Act No. 20 of 2015, the version for 2014 prints five clauses and no fee limb where the 2015 one has six, and section 52 of the Finance Act, 2015 itself says it. Rajesh Kourani, Sajeev Mathew, Conceria International, Dundlod, Bugalia and Vodafone Idea were each read in their own text and the quotations are from those readings. Fatheraj Singhvi has not been read in its own text, so what is said about the Karnataka decision is what the judgments that have been read record of it; Sarala Memorial Hospital likewise, as Sajeev Mathew describes it. Rashmikant Kundalia was read in its own text; the Supreme Court granted leave against it on 3 January 2017 and that appeal is pending. Not closed: any special leave petition against Fatheraj Singhvi, Rajesh Kourani, Dundlod or Conceria, and any High Court movement since 10 November 2023 — no Supreme Court decision resolving the split has been traced; the amending Act for clause (c) of section 154(1), which carries no footnote marker in any version read; and the overlap between the six-year second proviso to section 200(3) and section 397(3)(f) of the 2025 Act, which fixes two years and is drafted to reach statements required under section 200 of the 1961 Act, where the Board's transition FAQ says corrections for FY 2025-26 and earlier stay under the 1961 framework. The worked fee illustration is the department's own and is a 1961-Act one. No source could be cited for that finding. Checking whether an authority still stands matters as much as knowing what it held: a decision may be overruled on one point and survive on another, or the provision it interprets may have been amended since. Read the source and the editor's note on this page before relying on it in a reply to an Assessing Officer or in an appeal.
Sources. The statutory text in `facts` is taken from the most recent published version of section 200A of the Income-tax Act, 1961 and checked clause for clause against the two published versions before it. The related provisions are taken from the current published texts of sections 234E, 156, 246A, 154 and 200. The successor provisions are taken from the current published texts of sections 399, 427, 397, 357, 356 and 536 of the Income-tax Act, 2025, and from the Board's transition FAQ. Nineteen published versions of section 200A have been read, from the oldest — which carries the pre-2014 five-clause text — to the latest. Amendment footnotes, quoted as they are printed. On the version published for 2015, footnote 16: "Clauses (c) to (f) shall be substituted for clauses (c) to (e) by the Finance Act, 2015, w.e.f. 1-6-2015." On the version for 2016, footnote 70: "Clauses (c) to (f) Sub. for clauses (c) to (e) by Act No. 20 of 2015 (w.e.f. 1-6-2015)." On the two most recent versions, footnotes 12-13 and 14, and 57 and 58: "Ins. by Act No. 15 of 2024, w.e.f. 1-4-2025." On section 234E as first published: "Inserted by the Finance Act, 2012, w.e.f. 1-7-2012." On section 246A, footnote 78: "Substituted for 'section 143, where the assessee objects' by the Finance Act, 2012, w.e.f. 1-7-2012" — and that is what dates the deductor's appeal right to 1 July 2012, the day section 234E came into force. On section 200, footnote 12-13: "Ins. by Act No. 15 of 2024, w.e.f. 1-4-2025", which is the second proviso to section 200(3). Arithmetic checked. The department's own illustration — quarter July to September 2025, due 31 October 2025, filed 4 April 2026, TDS Rs 8,400 — gives 30 + 31 + 31 + 28 + 31 + 4 = 155 days, 155 x 200 = Rs 31,000, capped by section 234E(2) at Rs 8,400. 2026 is not a leap year. Two things this page does not settle. Fatheraj Singhvi v. Union of India (Karnataka, 2016) and Sarala Memorial Hospital v. Union of India (Kerala, W.P.(C) No. 37775 of 2018) each need reading in their own text and a record of their own; until then the Karnataka and Kerala positions are stated on the authority of the judgments that discuss them. And clause (c) of section 154(1), the limb that allows rectification of a section 200A intimation, carries no amendment footnote in any version read, so the record asserts only that the clause is there, and not who put it there. This library shows the verification state of every entry openly. This entry has not yet been read in full by a chartered accountant. The summary reflects the sources listed on this page. Read the source before you rely on it in a reply to an Assessing Officer or in an appeal before the Commissioner (Appeals) or the Income Tax Appellate Tribunal.
Section 200A prescribes how the department processes a TDS statement and what it may put into the resulting intimation. It does not create a charge. Its own text was last changed on 1 April 2025; the Act that contains it was repealed with effect from 1 April 2026, and the last paragraph below sets out what still runs on it and what has replaced it. The position under section 200A is this. Sub-section (1) applies to a statement under section 200 and, since the Finance (No. 2) Act, 2014 (Act No. 25 of 2014) with effect from 1 October 2014, also to a correction statement. Six things happen, in order. Clause (a) recomputes the sums deductible after adjusting for an arithmetical error or for an incorrect claim apparent from any information in the statement, and the Explanation confines an "incorrect claim" to an entry inconsistent with another entry in the same statement, or a rate of deduction that is not in accordance with the Act. Clause (b) computes the interest. Clause (c) computes the fee, if any, in accordance with section 234E. Clause (d) determines the sum payable or the refund due, after setting the clause (b) and clause (c) amounts against anything already paid under section 200, section 201 or section 234E and anything otherwise paid as tax, interest or fee. Clause (e) prepares or generates the intimation and sends it to the deductor. Clause (f) grants the refund. The clause lettering matters, and it changed. Until 31 May 2015 sub-section (1) ran (a) to (e), with no fee limb: (a) sums deductible, (b) interest, (c) sum payable or refund, (d) intimation, (e) grant of refund. The footnote on the version published for 2015 reads "Clauses (c) to (f) shall be substituted for clauses (c) to (e) by the Finance Act, 2015, w.e.f. 1-6-2015", and the footnote on the version published for 2016 reads "Clauses (c) to (f) Sub. for clauses (c) to (e) by Act No. 20 of 2015 (w.e.f. 1-6-2015)." Act No. 20 of 2015 is the Finance Act, 2015, and section 52 of that Act, assented to on 14 May 2015, says it in terms: "In section 200A of the Income-tax Act, in sub-section (1), for clauses (c) to (e), the following clauses shall be substituted with effect from the 1st day of June, 2015, namely:—", the first of the substituted clauses being "(c) the fee, if any, shall be computed in accordance with the provisions of section 234E;". So the section 234E fee limb entered section 200A(1) as clause (c) on 1 June 2015, and everything from the determination of the sum payable onwards shifted one letter down. A reference to "the intimation under section 200A(1)(d)" or "the refund under section 200A(1)(e)" is a reference to the law as it stood before 1 June 2015. The time limit is in the proviso to sub-section (1), not in sub-section (2). It reads: no intimation under this sub-section shall be sent after the expiry of one year from the end of the financial year in which the statement is filed. That proviso has stood in the same words in every published version of the section from 2010 onwards and has not been amended since section 200A took effect on 1 April 2010. Sub-section (2) is not a time limit at all — it is the Board's power to make a scheme for centralised processing, and it is unamended since 2010. Sub-section (3), inserted by the Finance (No. 2) Act, 2024 (Act No. 15 of 2024) with effect from 1 April 2025, gives the Board a further power to make a scheme for processing statements made by a person who is not a deductor; the same Act added the words "and other statements" to the marginal note. That 1 April 2025 change is the most recent amendment, and is why the current text is dated from that day. Section 234E, inserted by the Finance Act, 2012 with effect from 1 July 2012, is the charge. It fixes a fee of two hundred rupees for every day the failure to deliver the statement continues; sub-section (2) caps the fee at the amount of tax deductible or collectible; sub-section (3) requires the fee to be paid before the statement is delivered; sub-section (4) applies the section to statements to be delivered on or after 1 July 2012. It is a fee, not a penalty: the Bombay High Court in Rashmikant Kundalia v. Union of India (Writ Petition No. 771 of 2014, 9 February 2015, Mohit S. Shah C.J. and B.P. Colabawalla J.) dismissed the challenge to it and held it is not punitive but a fee, and that a separate penalty provision, section 271H, exists alongside it. That judgment is under appeal: the Supreme Court granted leave against it on 3 January 2017 and the appeal was still being listed in September 2024, so nothing has reversed it but its validity is not finally closed. The rate and the cap have not changed: the section as it now stands still reads "two hundred rupees" and still caps the fee at the tax deductible or collectible, and carries no footnote recording any change. The intimation is not a soft document. Under the proviso to section 156(1) an intimation under section 200A(1) determining a sum payable is deemed to be a notice of demand. It is appealable: section 246A(1)(a) lets any assessee or any deductor or any collector appeal to the Commissioner (Appeals) against an intimation under sub-section (1) of section 200A where the deductor objects to the making of adjustments. That right is older than the fee limb — the words "section 143 or sub-section (1) of section 200A, where the assessee or the deductor objects" were substituted for "section 143, where the assessee objects" by the Finance Act, 2012 with effect from 1 July 2012, the same day section 234E came into force, and the Finance Act, 2015 then widened the same clause to take in section 206CB and the collector with effect from 1 June 2015. Rectification also lies: section 154(1)(c) expressly empowers an income-tax authority to amend any intimation under sub-section (1) of section 200A, and a section 154 order enhancing the assessment, reducing a refund or refusing the claim is itself appealable under section 246A(1)(c). An intimation under section 200A is not an order under section 201. The Delhi High Court in Vodafone Idea Ltd v. ACIT (W.P.(C) 2729/2026 and connected petitions, 18 August 2026) held that sections 200A and 201 operate on entirely different fields and spheres, and that once an order under section 201, or an appellate order arising from it, finds an amount refundable, that is a vested and crystallised right which cannot be withheld except by an order actually passed under section 245. The route to fix a statement, as opposed to fixing the intimation, is the correction statement under the first proviso to section 200(3), read with rule 31A. Rule 31A(2) as substituted by the Income-tax (Eleventh Amendment) Rules, 2016 with effect from 1 June 2016 fixes the quarterly due dates at 31 July, 31 October, 31 January and, for the quarter ending 31 March, 31 May of the following financial year, uniformly — the earlier separate, later date for Government offices, which the Gujarat High Court upheld against an Article 14 challenge in Rajesh Kourani, is no longer in the rule. The second proviso to section 200(3), inserted by the Finance (No. 2) Act, 2024 with effect from 1 April 2025, now bars a correction statement delivered after six years from the end of the financial year in which the original statement was due. The live dispute is whether a section 234E fee can be charged in a section 200A intimation for a period before 1 June 2015, when section 200A(1) carried no fee limb. The High Courts are divided and there is no Supreme Court decision resolving it. On the deductor's side: the Karnataka High Court in Fatheraj Singhvi v. Union of India (2016) held that because the amendment to section 200A took effect on 1 June 2015 and is prospective, no computation of the fee could be made in an intimation for an earlier period. The Kerala High Court has taken the same view — in Sajeev Mathew and Company v. ITO (TDS), Kochi (W.P.(C) No.24533 of 2021, Bechu Kurian Thomas J, 30 November 2021), following its own earlier decision in Sarala Memorial Hospital v. Union of India, the Court recorded that "it was held that the amendment would take effect only with effect from 1st June, 2015 and is thus prospective in nature", and ordered: "Accordingly, I quash Ext.P1 notice to the extent it demands fee under section 234E for the period from 2011-12 till 01.06.2015." The Bangalore Bench of the Tribunal applied Fatheraj Singhvi in Kooud Software P Ltd v. DDIT (CPC) — TDS (ITA Nos.82 to 90/Bang/2022, 25 March 2022) and deleted the pre-June-2015 levies, on the footing that it is bound by its jurisdictional High Court. On the Revenue's side: the Gujarat High Court in Rajesh Kourani v. Union of India (Special Civil Application No. 302 of 2014, Akil Kureshi and Biren Vaishnav JJ, 20 June 2017) dismissed the petition, holding at paragraph 19 that "section 200A of the Act is a machinery provision... On the other hand, section 234E is a charging provision creating a charge for levying fee for certain defaults in filing the statements. Under no circumstances a machinery provision can override or overrule a charging provision", and at paragraph 20 that "Even in absence of section 200A of the Act with introduction of section 234E, it was always open for the Revenue to demand and collect the fee for late filing of the statements. Section 200A would merely regulate the manner in which the computation of such fee would be made and demand raised." The Rajasthan High Court had already gone the same way two years earlier, in M/s Dundlod Shikshan Sansthan v. Union of India (D.B. Civil Writ Petition No. 8672/2014, Sunil Ambwani CJ and Veerendr Singh Siradhana J, 28 July 2015), which dealt with the point squarely and not merely as a question of vires: "In the present case, the fee was levied under section 200 for late filing of the returns, prior to the amendments made by the Finance Act, 2015 with effect from 1.6.2015 in Sections 200A, 246A and 272A providing for computation and appeal. We do not find that even prior to these amendments the imposition of fee was illegal." The writ petition was dismissed as having no merit, and the Jaipur Bench of the Tribunal has since followed it as binding in Shri Jagdish Prasad Bugalia v. ITO (TDS)-3 (ITA No. 704/JP/2017, 15 February 2018). The Madras High Court in Conceria International P Ltd v. ITO (W.P. No.16934 of 2021, Mohammed Shaffiq J, 10 November 2023) agreed with Gujarat and Rajasthan, relying on section 234E(1) as the substantive provision, section 234E(3) as providing for self-assessment and payment of the fee before the statement is delivered, and section 234E(4) as fixing 1 July 2012 as the operative date, and said in terms: "With due respect I am unable to subscribe to the view expressed by the Karnataka High Court in view of the reasons stated supra." The petition was dismissed and the challenge to the levy of late fee prior to 1 June 2015 was rejected. Rashmikant Kundalia is not authority on this split. It decided that section 234E is constitutionally valid; it did not decide whether the fee could be collected through a section 200A intimation before 1 June 2015. In Rajesh Kourani the petitioner's counsel expressly abandoned the constitutional challenge because of Rashmikant Kundalia and argued only the machinery point. How long this text governs. Section 536(1) of the Income-tax Act, 2025 provides that "The Income-tax Act, 1961 (43 of 1961) is hereby repealed", with effect from 1 April 2026. Section 536(2) saves what was done under it: nothing affects the previous operation of the repealed Act, or any right, privilege, obligation or liability acquired, accrued or incurred under it, and the provisions of the repealed Act continue to apply to any proceeding pending at commencement and to proceedings initiated on or after 1 April 2026, including notices, rectification, penalty and appeals. So everything above still governs a statement for any quarter up to and including the quarter ended 31 March 2026, and the intimation, rectification and appeal that follow from it, however late they come. The Board's transition FAQ puts the fence where the statement is filed rather than where the intimation lands: the statement for Q4 of FY 2025-26 (January to March 2026) is filed under the 1961 Act in Forms 24Q, 26Q, 27Q and 27EQ by 31 May 2026, while the statement for Q1 of tax year 2026-27 (April to June 2026) is filed under the 2025 Act in the new forms by 31 July 2026 and Q2 by 31 October 2026. For an obligation rather than a statement, the FAQ's rule is that the Act governing the deduction is fixed by the earlier of credit or payment — on or before 31 March 2026 the 1961 Act, on or after 1 April 2026 the 2025 Act. Under the 2025 Act the successor to section 200A is section 399, "Processing". The clause lettering survives intact: sub-section (1) runs (a) to (f), with the fee at clause (c) — "the fee, if any, shall be computed as per the provisions of section 427(1) and (2)" — the determination at (d), the intimation at (e) and the grant of the refund at (f). Two things move. The one-year limit is no longer in a proviso to sub-section (1): section 399(2) reads "The intimation under this section shall be sent within one year from the end of the tax year in which the statement is filed", and the Board's scheme power drops to sub-section (3). And section 399(1) is written to cover statements of tax collected at source as well as tax deducted at source, which section 200A did not. The fee itself is section 427: Rs 200 for every day the failure continues, not exceeding the amount of tax deductible or collectible, and payable before the statement is delivered — the same rate and the same cap. The appeal survives in the same terms: section 357(c) makes appealable before the Commissioner (Appeals) "an order being an intimation under section 270(1) or 399(1), where the assessee or the deductor or the collector objects to the adjustments made therein", and section 356(a) carries the identical entry for the Joint Commissioner (Appeals). The correction statement moves to section 397(3)(f), and the window there is two years, not six.
TaxSphere, “Statutory position — s.200A: the CPC computes tax, interest and the s.234E fee on a TDS statement and issues an intimation”, https://taxnotice.vittsphere.com/caselaw/case/statutory-position-200a-processing-a-tds-statement-and-the-234e-fee/ (validity last checked 2026-09-23)
The judgment itself is a government work and may be quoted freely. The summary, the validity note and the reasoning on this page are this library's own writing: quote them with attribution, and please do not present either as the words of the court — this page keeps the two apart and so should a quotation of it.
Every entry in this library links to where it was found, so you can check it yourself rather than take our word for it.
CPC has raised a short-deduction demand on me because my payee's PAN was inoperative for want of Aadhaar linking. What exactly does an inoperative PAN do, and is there any Board relief?
In March 2026 I remitted a fee to a company outside India without deducting anything, because I did not think any part of it was taxable here. The Assessing Officer now says section 195 obliged me to deduct on the whole remittance, or at least to apply to him before paying. Does section 195 say that — and since the new Act has come in, which Act governs my payment at all?
Is there High Court authority that the s.234E fee runs from 1 July 2012 whatever the 2015 amendment to s.200A did, and does paying the fee buy me out of s.271H penalty?
CPC has charged s.234E fee in a s.200A intimation for TDS quarters going back to 2010-11. My consultant says the Karnataka High Court struck that down. Does that help me in Tamil Nadu?
