Tds on warehouse management charges

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Querist : Anonymous

Querist : Anonymous (Querist)

21 February 2012 We have warehouses at different location and provide warehouse management services to our client. it includes transportation, loading, unloading, packing, distribution on behalf of client. it means we are not only letting out warehouse but also providing other services. now, question is TDS rate on above. above payments whether covers under 194C or 194I. pls suggest with justification.

thanks in advance

CMA Ramesh Krishnan

CMA Ramesh Krishnan (Expert)
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21 February 2012 If you provide the different bills for hire & other services, the TDS applicable different section. Hire- u/s.194I & other services-194C

if combined bills then only one section 194I apply for total bills

Querist : Anonymous

Querist : Anonymous (Querist)

22 February 2012 In above case essence of the service is not letting out the warehouse but it is overall management of the warehouse, so i think 194 I is not applicable, this rather 194 C. if we segregate (on rational basis)the total bill amount than warehouse rent goes only to 20% of the total bill amount. thus covering entire bill under 194 I is not justify and also as per circular 715/1995 clarifies that when composite agreement is in essence of the tenancy agreement only than 194 I is applicable.

Querist : Anonymous

Querist : Anonymous (Querist)

Aashok Kumar Sharma

Aashok Kumar Sharma (Expert)
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27 July 2025 Hey! On **TDS for warehouse management charges** with both rent and services (transport, loading, unloading, packing, distribution) combined, here’s the clear picture based on the discussion and tax provisions:

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### Sections involved:

* **Section 194I**: TDS on **rent of immovable property** (including warehouse rent) — generally at 10%
* **Section 194C**: TDS on **contractual services** like transportation, loading/unloading, packing, etc. — generally at 1% (for individual/HUF) or 2% (others)

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### Key points:

* If the invoice is **split into rent and service components**:

* Deduct TDS on rent part under **194I**
* Deduct TDS on service part under **194C**

* If the invoice is a **composite bill covering rent + services (overall warehouse management)**:

* Since the *main essence* is not merely renting out the warehouse but providing a **management service**, the entire payment may be considered a service contract, hence TDS should be deducted under **194C** on the full amount.

* This interpretation is supported by **CBDT Circular No. 715/1995**, which clarifies that 194I applies only when the **essence of the agreement is tenancy/letting out property**. If it is composite but essence is services, then 194C applies.

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### Practical approach:

| Scenario | Section for TDS | Rate\* | Remarks |
| ------------------------------------- | ----------------------------- | --------------------------- | ----------------------------- |
| Separate rent & services billed | 194I (rent) & 194C (services) | 10% (rent), 1/2% (services) | Segregate amounts for clarity |
| Composite bill (warehouse + services) | 194C | 1/2% | Considered service contract |

\*Rates depend on whether the payee is individual/HUF or others.

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If you want, I can help draft a note or TDS clause based on your case. Also, you may want to get the payee’s PAN to avoid higher TDS rates.

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