This discussion clarifies whether TDS under Section 194Q is deductible on advance payments made in FY 2020-2021 for bills raised in FY 2021-2022 after 01/07/2021. The consensus is that Section 194Q applies only to payments or credits made on or after 01/07/2021. Therefore, if either the payment or credit occurred before this date, TDS is not applicable, even if the bill is raised later. However, if the threshold is met upon booking the actual invoice after 01/07/2021, tax may be deductible on the excess amount.
30 May 2022
Dear Sir, Whether TDS Under Section 194Q Deductible on advance Payment MADE IN FY 2020-2021 against which Bill Raised in FY 2021-2022 after 01/07/2021.
30 May 2022
The Finance Act, 2021, has inserted Section 194Q with effect from 01-07-2021. Thus, provisions of this Section shall not apply on any payment made or credit made in the books of accounts before 01-07-2021. Consequently, it would apply to all purchases made on or after 01-07-2021.
In simple words, the tax should be deducted where the payment is made or amount is credited on or after 01-07-2021. Thus, where any of the trigger event (i.e., payment or credit) has occurred before the date of applicability of provision, no liability to deduct tax will arise.
However, while booking the actual invoice, if the threshold limit has crossed, and other conditions are satisfied, the buyer has to deduct the tax on the amount exceeding the threshold limit as on the date of booking the actual invoice.