02 January 2010
Our Client "A" is deducting TDS on payment, on behalf of their group companies and raising debit note to group companies, in this case: 1) is tds on whole amount is allowable to "A"? and 2) are group companies liable to deduct tds on payment to "A"?
27 July 2025
Great question! Here’s the clarification on **TDS deduction when payment is made on behalf of group companies:**
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### Scenario:
* Company **A** pays a vendor and deducts TDS on the entire payment amount. * Company **A** then raises a debit note to its **group companies** (say B, C, D) for their respective shares of the payment.
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### 1) **Is TDS on the whole amount allowable to Company A?**
* **Yes, Company A can claim the credit for TDS deducted on the full amount** paid to the vendor because the payment was actually made by Company A. * The tax deducted at source is credited to the PAN of the person/entity deducting the TDS, i.e., Company A. * Company A will get TDS credit against its own tax liability.
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### 2) **Are group companies liable to deduct TDS on payment to Company A?**
* Yes, **group companies (B, C, D) need to deduct TDS on the amount they pay to Company A** (i.e., on the debit notes raised by A). * This is because **the payment from group companies to Company A is a separate transaction** and is subject to TDS as per applicable sections. * So, TDS has to be deducted again at the time of payment to A by the group companies.
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### Summary:
| Aspect | TDS Treatment | | -------------------------------------------------- | ------------------------------------------------------------ | | Payment & TDS by Company A | TDS deductible and credit allowed to Company A | | Debit note payment by group companies to Company A | Group companies must deduct TDS on amounts paid to Company A |
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### Important points:
* Company A should provide **TDS certificates** to group companies for the TDS it has deducted on vendor payments. * Group companies should account for TDS on payments to A, as they are making a fresh payment. * This ensures TDS is correctly deducted on each leg of the transaction and proper credit is available to all parties.
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If you want, I can help with drafting an example journal entry or provide relevant sections/rules. Would that be helpful?