TDS Notices — How Do You Reconstruct the Reasoning Behind a Rate?

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Fellow CAs,

A genuine question from something I have been thinking about deeply.

When a client receives a Section 201 notice questioning a TDS rate — the IT department is not asking what was deducted. They are asking why that specific rate was applied on that specific transaction.

Most ERPs store the outcome — amount, section, rate, vendor PAN. None store the decision logic behind it — why that section over another, why that rate given the deductee type, what the YTD aggregate was at that exact payment moment, what PAN status was on that date.

In practice, how are you handling this when a notice arrives? Are you reconstructing from vendor master configuration, emails, 
or something else?

We are building RegInfra — a TDS API that stores the complete decision chain behind every calculation at the moment it happens. Built for Income Tax Act 2025. Still early and would genuinely value the perspective of practitioners who handle this regularly.

Would love your honest view — is this reconstruction problem real in practice or do existing tools handle it well?

reginfra.com

Replies (3)
Quick Summary
TDS notices often require explaining why a specific rate/section was applied. Since most ERPs store only outcomes, professionals must reconstruct logic using vendor data, PAN status, contracts, and thresholds-making this a real and time-consuming challenge.

Yes, the issue is genuine. In many cases, TDS notice handling requires reconstructing the logic from vendor master, contracts, PAN status, thresholds, and supporting records because most systems store the result, not the full reasoning trail.

Thank you for this — really helpful to hear from someone who handles this in practice.

Two follow-up questions if you don't mind:

1. When you reconstruct the logic for a notice, roughly how long does it typically take per transaction? Is it hours or days?

 

2. Do your clients (or their ERPs) typically have any of this stored — or is it always a reconstruction from scratch?

The Income Tax Act 2025 renumbered all TDS sections from April 1, 2026, so Section 194J is now Section 393 and Section 194C is now Section 392 ,  if your notice references an old section number while your returns used the new ones, that often explains the mismatch rather than the rate itself being wrong. For reconstructing the rate, you need three things: the payment date, the nature of the payment (contract vs. professional vs. salary), and whether the payee had a lower-deduction certificate in force at that time. If the rate itself is disputed, the assessing officer's worksheet in the notice will show you what rate they expected so you can compare directly against the section and thresholds. The new section numbering and how TDS certificates changed this year are covered in this [Form 130 TDS certificate guide](https://taxgarden.in/blog/form-130-replaces-form-16-tds-certificate-2026).

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