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

Sri Sita Ram Rai, Dhanbad vs. ITO TDS Ward, Dhanbad

In the result, both the appeals of the assessee stand allowed

ITA 14/RAN/2022[2014-15]Status: DisposedITAT Ranchi28 Apr 2023AY 2014-15

Bench: Shri Sanjay Garg & Shri Rajesh Kumari.T.A. Nos.13&14/Ran/2022 Assessment Years: 2013-14 & 2014-15 Sri Sita Ram Rai……..….…..…………..…...…......................……...…..….. Appellant 1, New Karmik Nagar, Ism Saraidhella, Dhanbad, Jharkhand - 826004. [Pan: Afipr2324B] Vs. Ito, Tds Ward-Dhanbad………………………….……….…………….. Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Pranob Kumar Koley, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : March 01, 2023 Date Of Pronouncing The Order : April 28, 2023 Order Per Sanjay Garg: Both The Appeals Have Been Preferred By The Assessee Against The Separate Orders Dated 15.03.2022 Of The National Faceless Appeal Centre [Hereinafter Referred To As The ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). The Assessee In Both The Appeals Has Agitated The Levy Of Late Filing Fees U/S 234E Of The Act Along With Interest Thereupon Levied U/S 220(2) Of The Act. Since, Common Issues Are Involved In All The Appeals, Hence These Have Heard Together & Are Being Disposed Of By This Common Order. The Appeal In Ita No.13/Ran/2022 For Assessment Year 2013-14 Is Taken As Lead Case For The Purpose Of Narration Of Facts. 2. The Brief Facts Of The Case Are That The Assessee Deducted Tax At Source (Tds) In Respect Of Certain Payments. As Per The Provisions Of 1

Section 200(3)Section 200ASection 220(2)Section 234ESection 250

Sri Sita Ram Rai, Dhanbad vs. ITO, Dhanbad

In the result, both the appeals of the assessee stand allowed

ITA 13/RAN/2022[2013-14]Status: DisposedITAT Ranchi28 Apr 2023AY 2013-14

Bench: Shri Sanjay Garg & Shri Rajesh Kumari.T.A. Nos.13&14/Ran/2022 Assessment Years: 2013-14 & 2014-15 Sri Sita Ram Rai……..….…..…………..…...…......................……...…..….. Appellant 1, New Karmik Nagar, Ism Saraidhella, Dhanbad, Jharkhand - 826004. [Pan: Afipr2324B] Vs. Ito, Tds Ward-Dhanbad………………………….……….…………….. Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Pranob Kumar Koley, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : March 01, 2023 Date Of Pronouncing The Order : April 28, 2023 Order Per Sanjay Garg: Both The Appeals Have Been Preferred By The Assessee Against The Separate Orders Dated 15.03.2022 Of The National Faceless Appeal Centre [Hereinafter Referred To As The ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). The Assessee In Both The Appeals Has Agitated The Levy Of Late Filing Fees U/S 234E Of The Act Along With Interest Thereupon Levied U/S 220(2) Of The Act. Since, Common Issues Are Involved In All The Appeals, Hence These Have Heard Together & Are Being Disposed Of By This Common Order. The Appeal In Ita No.13/Ran/2022 For Assessment Year 2013-14 Is Taken As Lead Case For The Purpose Of Narration Of Facts. 2. The Brief Facts Of The Case Are That The Assessee Deducted Tax At Source (Tds) In Respect Of Certain Payments. As Per The Provisions Of 1

Section 200(3)Section 200ASection 220(2)Section 234ESection 250