Please Help: TDS

I have filed Correction Statement (Return) for TDS of My Client, I Received Demand Notice in which TDS of 20% is Payable on PAN which were corrected in Correction Statement & the difference between the Invalid (PAN Mentioned in First TDS Return) and Valid PAN (PAN Mentioned in Correction Statement) is more than 2 alphabets and /or 2 numeric characters. Is there any Provision/Circular/Notification in Income Tax Act that specify that If the difference between the Invalid PAN (PAN Mentioned in First TDS Return) & Valid PAN (PAN Mentioned in Correction Statement) is more than 2 alphabets and /or 2 numeric characters, then TDS should is Deducted @20%, also Specify such Notification. Thank You.