Section 200A of the Income Tax Act

Income-tax Act, 2025: s.399

Section 200A of the Income-tax Act, 1961 corresponds to section 399 (Processing) of the Income-tax Act, 2025.

Read section 399 of the 2025 Act

Correspondence checked against the ICAI tabular mapping of the two Acts and the BharatTax.co section commentary.

The decision most relied on for Section 200A is Fatehraj Singhvi v. UOI (73 Taxmann.com 252), cited in 1,778 of the 4,379 judgments on BharatTax that turn on this section.

Leading authorities on Section 200A

Fatehraj Singhvi v. UOI
73 Taxmann.com 252 · 2016 · High Court
1,778
citing judgments

Late fees under section 234E are not applicable for periods prior to June 1, 2015, as the amendment to section 200A inserting clause (c) was effective from that date.

Kourani v. Union OF India
83 Taxmann.com 137 · 2017 · High Court
1,708
citing judgments

The fee under Section 234E for late filing of TDS/TCS statements cannot be levied retrospectively by processing an intimation under Section 200A for defaults occurring before the amendment allowing such processing.

CIT v. Vatika Township Pvt. Ltd.
367 ITR 466 · 2014 · Supreme Court
1,558
citing judgments

Taxing statutes are presumed to operate prospectively unless a clear contrary intention for retrospective application is evident. The law applicable for determining tax liability is that which stands on the first day of the assessment year, following the principle that law looks forward, not backward (lex prospicit non respicit).

Fateh Raj Singhvi & Ors. v. UOI
289 CTR 602 · 2016 · High Court
844
citing judgments

A fee under Section 234E cannot be levied or adjusted in an intimation under Section 200A for TDS statements pertaining to periods prior to June 1, 2015, as the enabling amendment to Section 200A(1)(c) came into effect only from that date.

Rashmikant Kundalia v. Union of India
54 Taxmann.com 200 · 2015 · High Court
702
citing judgments

Section 234E, levying late fees for delayed filing of TDS statements under section 200(3), is constitutionally valid and constitutes a compensatory fee, not a punitive penalty. Before treating any person as an assessee-in-default, an opportunity of being heard must be provided.

Olari Little Flower Kuries (P.) Ltd. v. UOI
440 ITR 26 · 2022 · High Court
614
citing judgments

The fee under Section 234E of the Income-tax Act cannot be levied for defaults in filing TDS statements committed prior to June 1, 2015, as the provision for its levy became effective only from that date.

Gajanan Constructions v. DCIT
74 Taxmann.com 6 · 2016 · ITAT
465
citing judgments

Late fees under section 234E can only be levied prospectively from June 1, 2015. Levying late fees for periods prior to this date is not permissible.

Dundlod Shikshan Sansthan v. Union of India
63 Taxmann.com 243 · 2015 · High Court
397
citing judgments

The imposition of fees for late filing of TDS/TCS returns prior to the Finance Act, 2015 amendments was not illegal, and the Rajasthan High Court found no justification to interfere with such compensatory fees.

Jiji Varghese v. ITO(TDS) & Ors.
443 ITR 267 · 2022 · High Court
220
citing judgments

Section 234E fee cannot be imposed for periods prior to June 1, 2015. This applies even when the processing of the return under Section 200A(c) occurred before that date.

Sree Narayana Guru Smaraka Sangam Upper Primary School v. Union of India and Others
392 ITR 457 · 2017 · High Court
217
citing judgments

Judgments on Section 200A

Pramod Kumar Manpuria, Ranchi vs. DCIT CPC TDS, Ghaziabad

In the result, all the three appeals of the assessee are allowed

ITA 54/RAN/2018[13-14]Status: DisposedITAT Ranchi24 May 2019

Bench: Shri Chandra Mohan Gargआयकर अऩीऱ सं./Ita No.50 To 54/Ran/2018 Assessment Year: 2013-2014(Q-2-26Q) Assessment Year: 2013-2014(Q-3-26Q) Assessment Year: 2013-2014(Q-4-26Q) Assessment Year: 2014-2015(Q-2-26Q) Assessment Year: 2014-2015(Q-1-26Q) M/S Pramod Kumar Manpuria Vs. Dcit, Cpc(Tds), C/O Modern Funishers Ghaziabad, Up Sujata Chow, Main Road, Ranchi-834001 C/O L.K.Saraf & Co. Chartered 2Nd Accountants, Floor, Chauhan Mansion, Lalji Hirji Road, Ranchi-834001 स्थायी ऱेखा सं./ जीआइआर सं./ Pan/Gir No. : Acnpm 3796 Q (अऩीऱाथी /Appellant) .. (प्रत्यथी / Respondent) यनधागररती की ओर से /Assessee By :Shri Saket Modi, Fca राजस्व की ओर से /Revenue By : Shri P.K.Mondal, Acit(Dr) सुनवाई की तारीख / Date Of Hearing : 24/05/2019 घोषणा की तारीख/Date Of Pronouncement 24/05/2019 आदेश / O R D E R These Appeals Have Been Filed By The Assessee Against The Common Order Of Commissioner Of Income Tax (Appeals), Ranchi, All Dated 31.10.2017 For The A.Y. 2013-2014(Q-2-26Q), A.Y. 2013- 2014(Q-3-26Q), A.Y. 2013-2014(Q-4-26Q), A.Y. 2014-2015(Q- 2-26Q) & A.Y. 2014-2015(Q-1-26Q), Respectively. 2. The Common Grievance Of The Assessee In All The Appeals Is That The Cit(A) Has Erred In Dismissing The Assessee'S Appeal In Respect Of Levy Of Late Fee U/S.234E Of The Act.

For Appellant: Shri Saket Modi, FCAFor Respondent: Shri P.K.Mondal, ACIT(DR)
Section 200Section 200ASection 234E