Application of section 206C(1H)

Sir, With regard to TCS-U/s.206C(1H) which was introduced from 01-10-2020, for removal of doubts, CBDT had issued a circular vide no.17 of 2020 dated 29/09/2020, vide F.No.370133/222020-TPL.

Vide point no. (iii) of 4.4.2 what I have understood is that

Threshold limit is of Rs.50.00 lacs is with regard to previous year ie. 01-04-2020 to 31-03-2021, and implementation is from 01-10-2020.

Senario-1: From 01-04-2020 to 30-09-2020 collections were 49.00 lacs and such collections are exceeded more than of Rs.50.00 lacs on 10-10-2020, hence, I will collect the TCS on the amount collected in excess of Rs.50.00 lacs.

Senario-2: From 01-04-2020 to 30-09-2020 collections were of Rs. 75.00 lacs, now from 01-10-2020, do I have to collect the TCS only on the collections received on after 01-10-2020 or on 01-10-2020 do I have to collect the TCS on Rs. 25.00 lacs as already collections were in excess of Rs. 50.00 lacs by 30-09-2020?

Kindly clarify.
Replies (2)
Quick Summary
This discussion clarifies the application of TCS under Section 206C(1H) introduced from 1st October 2020. It addresses how the Rs 50 lakh threshold for previous financial year collections interacts with the implementation date. The consensus is that TCS is applied to amounts exceeding the threshold, and importantly, tax is only collected on transactions occurring on or after 1st October 2020, not on amounts collected prior to that date, even if the previous year's total exceeded the limit.

S1: Right, tax to be collected at source on receipts exceeding 50 lacs S2: Tax to be collected only on all the receipts on/after 1st Oct 2020 (no need to collect tax on 25 lacs received prior to Oct)
1, After Crossing the limit of Rs.50 Lakhs, 0.01% is charged as TCS from coming invoices.
It's charged on the invoice value.

2,No , From 1st Oct-2020 , 206C(1H) Applies.


Turnover of 10 Crore and 50 Lakhs are including GST.

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