Form 144 (Earlier 27Q) – Reason Code (A/C/G/Y) for DTAA deduction u/s 1057 – Figma Inc. (USA)

Dear Experts,

I am filing Form 144 (earlier Form 27Q) for FY 2026-27, Q1 using the latest Protean RPU Version 1.1 and FVU Version 1.1.

Facts:

  • Deductee: Figma Inc., USA
  • Nature of payment: Monthly Figma software subscripttion (SaaS)
  • TDS deducted @ 10% under the India–USA DTAA
  • Valid PAN, TRC and Form 10F are available.
  • Section Code: 1057
  • Rate as per: DTAA (B)

Initially, the FVU was giving the following errors:

  • T-FV-4335 – Invalid Email ID
  • T-FV-4336 – Invalid Contact Number
  • T-FV-4337 – Invalid Address
  • T-FV-4338 – Invalid Tax Identification Number

After verifying, all these details are correctly entered in the RPU. Surprisingly, the errors disappear only when I select a value in the field:

"Reason for non-deduction / lower deduction / higher deduction (Column AB)"

The dropdown contains only the following codes:

  • A
  • C
  • G
  • Y

However, the RPU does not display the meaning of these codes.

My queries are:

  1. What is the meaning of A, C, G and Y in Column AB of Form 144?
  2. Which code should be selected where:
    • TDS is normally deducted @ 10% under DTAA,
    • There is no lower deduction certificate,
    • There is no higher deduction,
    • PAN, TRC and Form 10F are available?
  3. Is this a known issue/bug in Protean RPU/FVU Version 1.1, where leaving Column AB blank incorrectly results in errors relating to Email, Contact Number, Address and TIN?

Any guidance from members who have successfully filed Form 144 for foreign payments would be highly appreciated.

Thank you.

Replies (4)
Quick Summary
This discussion addresses confusion regarding reason codes (A/C/G/Y) in Column AB of Form 144 (formerly 27Q) when claiming DTAA benefits for foreign payments, specifically for Figma Inc., USA. The user encountered validation errors in the Protean RPU/FVU software when leaving this field blank, which seemed to incorrectly trigger issues with contact details. It was clarified that selecting 'Y' (DTAA benefit claimed under Section 90/90A) resolves these FVU errors, and that certain deductee details might be optional when DTAA benefits are applied.

  • Code to Select: Y (DTAA benefit claimed under Section 90/90A).

  • Validation Errors: Leaving Column AB blank causes the schema to default to standard Act rates and trigger non-resident detail validation errors. Selecting Code Y resolves these FVU errors.

Solution for your Queries::

  1. refer Annexure -6 of the enclosed sheet below.
  2.  Select code - B for DTAA rate of tax.
  3. email, contact number, address and TIN of the deductee were optional values. leave it blank. 
  4. Field AB value are also optional. leave it blank.

if you have any quiries pls let me know. will clear all your doubts. recetly i filed form 144

https://tinpan.proteantech.in/downloads/e-tds/eTDS-download-regular.html

Download the data structure format "" 

  • File Format for Form Number 144 Q1 to Q4 Version 1.0 ""

Form 144 reason code works as follows for DTAA claims on foreign payments:

- Code A: Lower rate under DTAA treaty. Use this when you are deducting at the treaty rate (say 10% FTS under India-USA DTAA) instead of the standard Section 115A rate of 25%.
- Code G: Nil deduction. Only valid if the deductee holds a certificate from the Assessing Officer allowing nil TDS.
- Code C: Standard rates apply, no DTAA claimed.
- Code Y: Exempt category (not applicable for SaaS payments).

For a SaaS payment to Figma Inc (USA) with no lower deduction certificate:
- If Figma has submitted a Tax Residency Certificate (TRC) and Form 10F, use Code A with the applicable DTAA rate.
- If Figma has NOT submitted TRC or Form 10F, you cannot apply the DTAA rate. Default rate (25% under Section 115A or 20% if no PAN with 20% slab) applies. Use Code C.

For deductee validation: Figma likely has no Indian PAN. In that case, use PANNOTAVBL as PAN, attach the TRC and Form 10F, and the Form 144 system should accept it.

This [India-USA DTAA guide](https://taxgarden.in/blog/dtaa-india-usa-double-taxation-avoidance-agreement-guide) covers TRC, Form 10F requirements, and applicable TDS rates for software and FTS payments.

I am a non CA and will have to file form 144 as I will be paying rent to an NRI landlord who has not furnished a lower deduction certificate. The amount will be deposited to their Indian NRO account. The property is co-owned by a couple. I had a few questions if someone can please answer them I would be really grateful:

    1. If both landlords have active Indian PANs, do I need form 145/146 as I will be paying rent in NRO account? What if the annual rent exceeds 5 lakhs? Does this change?
    2. What should be the country of remmitance?Will it be the country in which they reside?
    3. My understanding is, the status will be 02,  section code will be 1057 and nature of remittance would be income by way of renting or leasing out any real estate.
    4. While I have their TIN, adrress, contact number etc. is it mandatory to fill it if they have an active PAN? Are these fields mandatory if rent exceeds 5 lakhs?
    5. Whether rate of TDS is per act (c) or DTAA (b) - I will be choosing (a) since no lower deduction certificate is provided. Is the understanding correct?
    6. What should I chose in the field "reason for lower deduction/non-deduction/higher deduction"? Is this a mandatory field?

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