TDS on Brand Ambassador Fees

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Marimuthu (Querist)
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27 January 2024 Dear Experts,
1 A company is remitting the specified amount to its Chairman and Managing director towards Branch Ambassador Fees.
2 Whether the company needs to deduct the TDS u/s 194C or 194J

RAJA P M

RAJA P M (Expert)
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27 January 2024 Branch or Brand...?? If Brand then what is the product and what is the nature of service by the Director...? Bcoz, If the director is professional then 194J or others then 194C. But, We can't justify this with above question....

Marimuthu

Marimuthu (Querist)
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27 January 2024 Brand Sir,
Its for a Jewellery products,
The advertisment services on the television,cinema, malls etc.
He is not a educationally qualified for this activities

Aashok Kumar Sharma

Aashok Kumar Sharma

(Expert)
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13 August 2025 ✅ Applicable TDS Section: Section 194J – Fee for Professional or Technical Services
📌 Reason:
The services rendered (brand endorsement, acting in ads, etc.) fall under professional services as per Explanation (a) to Section 194J of the Income Tax Act, which includes:
"Services rendered by a person in the course of carrying on the legal, medical, engineering or architectural profession or the profession of accountancy or technical consultancy or interior decoration or advertising..."
Even though the CMD is not "educationally qualified" in advertising, brand endorsement and appearance in advertisements falls under the advertising profession, which is covered under Section 194J, not 194C.
❌ Why Not Section 194C (Contractual Services)?
Section 194C deals with contracts for carrying out any work including advertising.
But in the case of personal involvement in advertisement (e.g., as an actor, model, or brand face), it’s not just a work contract—it’s a professional service, and 194J is more appropriate.
💰 TDS Rate:
10% under Section 194J
If PAN is not available → TDS @ 20%
⚠️ Note on Director-Specific Cases:
Since the payment is to a director, you must also check whether it is covered under Section 194J(1)(ba):
TDS is to be deducted on any remuneration or fees or commission paid to a director which is not in the nature of salary.
If this Brand Ambassador fee is separate from salary, and not part of payroll (no PF, no perquisites, etc.), then Section 194J(1)(ba) is specifically applicable, and TDS @ 10% is to be deducted.

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