To summarize, while you may have heard that it is possible to "fight" the levy, this typically applies to periods prior to June 1, 2015, due to the lack of an enabling provision in Section 200A at that time. For any returns filed after that date, the fee is statutorily backed and mandatory. If you are dealing with a specific past demand from that period, you may wish to consult with a tax professional to determine if judicial precedents in your specific jurisdiction support a challenge.