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 (2)

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?


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