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TCS 206C for sale od motorized machinery

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This query is : Resolved

CA Pawan Koradia (Querist)

06 October 2025 We’re in the business of Selling Machinery, such as ACE Backhoe Loader and other motorised machinery (HSN 84295900). Whether TCS under Section 206C(1F) would be applicable on such sales, considering these as motor vehicles?

Dhirajlal Rambhia

Dhirajlal Rambhia (Expert)

06 October 2025 Backhoe loaders typically are registered and permitted to operate on public roads, so they usually qualify as "motor vehicles" under the Motor Vehicles Act, unless exclusively used in factory premises or off-road and not adapted for road use. Therefore, sales of such machinery to end-buyers (not dealers/distributors) for amounts exceeding ₹10 lakh would be subject to TCS @ 1% under Section 206C(1F).
The CBDT has clarified that Section 206C(1F) applies to retail sales to consumers, not sales from manufacturers to dealers/distributors. So, if the sale is to a dealer or distributor for further resale, TCS under this section does not apply, but if it is a direct sale to the end-user, it does.

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