Section 200A

What a section 200A notice is

TDS — Intimation / Default. A TDS statement has been processed and a default computed. It is a medium-severity notice in the tds family under the Income Tax Act 1961.

If you ignore it: Default stands, interest and late fee accrue.

Time to reply: commonly stated as 30 days from the date of the notice — but the date printed on your own notice governs, and it overrides any general figure. Very often a PAN or challan mismatch that corrects with a revised statement rather than a legal argument.

Section 200A — the law in short

What the courts have decided on section 200A, in one screen. Read this first; open an entry when you need the facts, the reasoning and the source.

• Vodafone Idea Ltd v ACIT (Delhi HC, 2026) High CourtHelps taxpayerNo later treatment found
  The Tribunal allowed my appeal, the Assessing Officer has passed the appeal effect order and worked out the refund, but the CPC will not pay because the portal shows an outstanding demand on my PAN and on my group TANs. Is that lawful?
  No. Once an appellate authority (or the Assessing Officer giving effect to its order) finds an amount refundable, that becomes a vested and crystallised right, and the Assessing Officer or the CPC cannot withhold a rupee of it except by an order actually passed under section 245. Where the Revenue could not produce any such order, the Delhi High Court held that refusing the refund because of demands standing against the assessee's PAN and sister TANs was untenable in law, arbitrary, and violative of Articles 14, 19(1)(g) and 300A, and directed payment of Rs 53,09,56,470 with interest under sections 244A and 244A(1A) by a fixed date, with a further 1 per cent per month if the date was missed.
• Srirangapattinam Desigan Srinivasan v DCIT (CPC-TDS) High CourtHelps taxpayerNo later treatment found
  I bought a flat, deducted one per cent under s.194-IA, and CPC has hit me with a demand because the seller's PAN was not linked to Aadhaar. Is there a High Court decision I can put in front of the officer?
  Yes. The Madras High Court disposed of a writ against exactly such a demand by holding that nothing survived for adjudication once Circular No. 6/2024 applied and the department had itself reprocessed the statement and reported no defaults. The judgment is worth having chiefly because it reproduces Circular No. 6/2024 in full, with its file number and date, which is otherwise hard to source.
• Conceria International P Ltd v ITO High CourtHelps departmentHigh Courts differ
  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?
  No. The Madras High Court set the Karnataka view in Fatheraj Singhvi against the Gujarat view in Rajesh Kourani, expressly declined to follow Karnataka, and held that s.234E is itself the substantive charge — it bites the moment the statement is late and does not wait for the s.200A(1)(c) machinery inserted on 1 June 2015. The waiver-rejection order was left standing, but the Court decided no separate question about a power of waiver.
• Sajeev Mathew and Company v ITO (TDS), Kochi High CourtHelps taxpayerHigh Courts differ
  I have a single consolidated s.234E demand covering 2011-12 right through to 2021-22. Can the old part be knocked out, and can I do it by writ?
  In Kerala, yes. The High Court quashed the demand notice to the extent it charged fee under s.234E for the period from 2011-12 up to 1 June 2015, holding that the insertion of clauses (c) to (f) in s.200A(1) took effect only from that date and is prospective. The rest of the demand was left standing.
• Rajesh Kourani v Union of India High CourtHelps departmentHigh Courts differ
  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?
  Yes on the first, no on the second. The Gujarat High Court held that s.234E is the charging provision and s.200A merely machinery, that a machinery provision cannot override a charging provision, and that even before 1 June 2015 the Revenue could always calculate and collect the fee. It also held, against Karnataka, that the s.234E fee is not in lieu of the s.271H penalty — the two are independent levies.
• Rashmikant Kundalia v Union of India High CourtHelps department
  I filed my TDS statement late and have been charged Rs.200 a day under section 234E — is that levy even constitutional when no service is given in return?
  Yes. The Bombay High Court upheld section 234E on 9 February 2015. The levy is not punitive: it is a fixed charge for the extra work the Department must do because the statement came in late, and the deductor gets something in return — his late filing is regularised and he is allowed to file beyond the prescribed time. That is a privilege and a special service, so the charge is a fee and not a tax in disguise. The absence of a power to condone delay and of a right of appeal does not make the section onerous, a right of appeal being a creature of statute. The writ petition was dismissed.
• Sanchit Gupta v DCIT (CPC), TDS ITATHelps taxpayer
  I bought a flat and deducted 1 per cent under s.194-IA. CPC has raised a 20 per cent short-deduction demand because the seller's PAN was inoperative for want of Aadhaar linking. The seller has since linked it. Is there any way out?
  Yes, but not the one most people reach for. The Delhi Bench held that the assessee fell outside the CBDT relief circulars on his dates, and that subsequent linking does not retrospectively cure the position. It nonetheless directed that no s.206AA liability be cast on him if the seller is shown to have declared the sale in her return and paid the tax, applying the Ansal Landmark principle by analogy, and remitted the matter for verification — observing that the department was equally responsible for not red-flagging inoperative PANs in its own system.
• Parul Sharma v ITO (TDS), Noida ITATHelps taxpayerNo later treatment found
  The CIT(A) refused me the benefit of the PAN-Aadhaar circular because he said I was relying on the wrong circular. Is there a Tribunal order that simply directs the officer to apply the extended date?
  Yes. The Delhi Bench set aside both the s.200A intimation and the CIT(A) order and directed the Assessing Officer to give the assessee the extended benefit of the CBDT circular of 23 April 2024 and pass a fresh order. It is a short order and the relief is a direction to apply the circular, not a deletion of the demand outright.
• Kooud Software P Ltd v DDIT (CPC) - TDS ITATHelps taxpayerHigh Courts differ
  The CIT(A) has confirmed my pre-June-2015 s.234E fee by following the Gujarat High Court, even though my jurisdictional High Court has decided the other way. Is the Tribunal bound to follow my own High Court?
  Yes. The Bangalore Bench held that the Karnataka High Court's decision in Fatheraj Singhvi is the binding decision of the jurisdictional High Court, and deleted the s.234E fee for all nine quarters, notwithstanding that the CIT(A) had preferred the Gujarat High Court's contrary decision in Rajesh Kourani. The fee under s.234E cannot be levied without the machinery provision of s.200A.
• Statutory position — s.200A: the CPC computes tax, interest and the s.234E fee on a TDS statement and issues an intimation CBDT Circulars & InstructionsCuts both waysSuperseded by amendment
  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.
• Statutory position — section 139AA(2) and rule 114AAA: what an inoperative PAN actually does, and the CBDT circulars that undo it CBDT Circulars & InstructionsCuts both ways
  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?
  An inoperative PAN carries four consequences and only four, and rule 114AAA(3) lists them: no refund of tax is made, no interest is payable on that refund for the period, tax deductible under Chapter XVII-B is deducted at the higher rate under section 206AA, and tax collectible under Chapter XVII-BB is collected at the higher rate under section 206CC. The third and fourth of those fall on the DEDUCTOR or COLLECTOR, not on the person who failed to link, which is why the demand lands on someone who did nothing wrong. The Board has issued a sequence of circulars relieving the deductor where the PAN is made operative by a date, and the sequence — Circular No. 3/2023 dated 28 March 2023, Circular No. 6/2024 dated 23 April 2024 and Circular No. 9/2025 dated 21 July 2025 — is the first thing to check, before any argument on merits.

Listed strongest first: Supreme Court, then High Court, then Tribunal, then CBDT. Nothing here has yet been read in full by a chartered accountant — open an entry to see where it came from.