Section 194R of the Income Tax Act generally applies to gifts provided for business promotion, meaning TDS is applicable. However, if the expenditure is for a group activity and individual recipient allocation isn't feasible, TDS under 194R may not be attracted. This interpretation is supported by Circular 18/2022.
09 November 2022
However, if it is for a group activity and a reasonable allocation of such expenditure is not possible recipient wise, 195R doesn't attract.