CA. Akhilesh Kumarcaakhilesh.in
DIRECT TAXThe TDS Calendar ThatPrevents Most NoticesMost TDS notices are calendar failures;deposit by the 7th and reconcile quarterly.CA Akhilesh Kumar· caakhilesh.inWHEN TDS ACTUALLY FALLS DUEDEPOSIT BY THE 7THQUARTER ENDS: THE STATEMENTMISS ONE AND THE INTEREST RUNS DAILY7thMonthlydepositdeadline2 weeksReconcileafter filing4 tasksRecurringcalendar tasksWHEN TDS ACTUALLY FALLS DUEDEPOSIT BY THE 7THQUARTER ENDS: THE STATEMENTMISS ONE AND THE INTEREST RUNS DAILYNº 18
Direct Tax · 7 min read · Summary infographic ↓

The TDS Calendar That Prevents Most Notices

Almost every TDS notice I see traces back to one of four things, and all four are calendar problems rather than technical ones. A working routine to avoid them.

By CA Akhilesh Kumar ACA, Institute of Chartered Accountants of India (2022) · Gurgaon
Direct TaxCorporate

TDS defaults are rarely caused by getting a section wrong. They are caused by dates — deducting late, depositing late, filing the return late, or not correcting a mismatch until the demand arrives. Those are process failures, and processes can be fixed.

Due dates and rates are amended periodically. Confirm the current position before relying on any date below.

The four failure modes

1. Deducting at the wrong time

The obligation generally arises at credit or payment, whichever is earlier — and it is the "credit" limb people miss. A provision entered at year end creates a deduction obligation even though nothing has been paid. Year-end provisioning without a TDS review is one of the most common sources of default.

2. Depositing late

Tax deducted must be deposited by the prescribed date of the following month, with a different date applying for March deductions. Late deposit attracts interest at a higher rate than late deduction — the Act deliberately treats holding on to someone else's deducted tax as the worse offence.

3. Filing the quarterly statement late

Late filing of the TDS return attracts a daily fee that runs until the statement is filed, capped at the amount of TDS. It accrues quietly and is not waived on request. Filing a statement late is expensive in a way that filing an imperfect statement on time is not.

4. Not reconciling

The deductee's credit comes from your statement. A wrong PAN, a wrong section, or a wrong assessment year means the deductee does not get credit and you get a short-deduction or PAN-error demand. These are almost always fixable by correction statement — but only if someone looks.

The routine

Four recurring tasks. Put them in a calendar, assign an owner, and most TDS problems disappear.

MONTHLY   by the 7th
          deposit last month's deductions
          (March deductions: separate date)

MONTHLY   before closing the books
          review new vendors and provisions
          for deduction obligations

QUARTERLY after each quarter ends
          file the statement
          then download and check Form 16A

QUARTERLY within two weeks of filing
          reconcile the statement against
          books and against Form 26AS/AIS
          file a correction if anything differs

Three habits that help

  • Collect PAN before the first payment, not before the first return. A missing or invalid PAN triggers deduction at a higher rate, and recovering that from a vendor after the fact is unpleasant.
  • Check whether the vendor holds a lower or nil deduction certificate before applying the standard rate — and check its validity period, which is not the financial year.
  • Reconcile 26AS and AIS quarterly, not annually. A mismatch found in July is a correction statement. The same mismatch found in the following March is a demand with interest.

Why it is worth the discipline

Beyond interest and fee, disallowance is the real cost. Expenditure on which tax was deductible but not deducted or deposited can be disallowed in computing business income — turning a modest compliance slip into a materially larger tax bill in the same year.

None of this is intellectually difficult. It is a calendar with an owner. The firms that have one rarely see a notice; the firms that do not see the same four notices every year.


General information, not professional advice. Specific obligations depend on the nature of the payment and the status of the parties.

Summary

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DIRECT TAXThe TDS Calendar That Prevents Most NoticesMost TDS notices are calendar failures; deposit by the 7th and reconcile quarterly.KEY FIGURES7thMonthly deposit deadline2 weeksReconcile after filing4 tasksRecurring calendar tasksTHE ROUTINE: FOUR TASKS01Monthly, by the 7thDeposit last month's deductions (March deductions: separate date)02Monthly, before closingReview new vendors and provisions for deduction obligations03Quarterly, after quarterFile the statement, then download and check Form 16A04Within two weeks of filingReconcile against books and Form 26AS/AIS; file a correction if anything differsCOMPARISON SNAPSHOTVSFour failure modesDeducting late: credit or payment, earlierDepositing late: interest at the higher rateFiling late: daily fee, capped at the TDSThree habitsCollect PAN before the first paymentCheck lower/nil certificates and validityReconcile 26AS and AIS quarterly, notannuallyDue dates and rates are amended periodically; confirm the current position before relying on any date.CA Akhilesh Kumarcaakhilesh.in

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