Query about cash withdrawals and tax/ITR filing implications

What are the tax liability or ITR filing requirements in case of cash withdrawals from savings accounts?
 
Details are as follows:
 
Senior citizens need to withdraw some cash from their savings accounts (held in individual names) for some expenses that need to be met in cash. The amount will be approximately 20-25 lacs
 
One of them is an income tax assessee and files ITR regularly. Other doesn’t file ITR due to income being below threshold. 
 
To avoid the 1% surcharge on cash withdrawals, they are planning to withdraw cash over multiple days at 2L per day each. About 15L to be withdrawn by the income tax assessee person and 5L by the other person who doesn’t file ITR today.  
 
The money held in the account is post-tax assessed/post-tax paid income in both cases so funds are completely legitimate. 
 
Main consideration is to ensure that they do not have to get into any new tax liabilities or  new ITR filing requirements due to this cash withdrawal. 
 
What are the potential implications of such cash withdrawal in this case?
Replies (7)
Quick Summary
Query relates to large cash withdrawals (20�25 lakh) from savings accounts by senior citizens and concerns about TDS, SFT reporting, and ITR implications. Experts clarify no direct tax liability arises if funds are legitimate and explainable, but transactions may trigger reporting and scrutiny.

Sec 269st deals with these provisions.

SEC 269ST IMPOSES RESTRICTIONS FOR WITHDRAWAL OF CASH OR RECEIVING CASH FROM SPECIFIED COMPANIES.

Will attract TDS

Will be reported in SFT

Notice Might trigger from ITAX for source of fund

Thanks Mahesh. 
 
1. Regarding TDS - if the withdrawals are in small amounts eg less than 2L per withdrawal, will there still be TDS deducted by the bank?
2. ⁠regarding reporting in SFT by bank - since the source of the funds is all post-tax income, with full traceability, it is completely legitimate funds. What are the implications for the withdrawing persons even if the transaction is reported in SFT by the bank?
3. ⁠ITD notice - again, since the funds being withdrawn are fully legitimate, is there anything the withdrawers need to be concerned about while withdrawing cash as described above?
 
The main concern of the people withdrawing this cash is to ensure that due to such withdrawals (a) there is no new tax liability that they will incur (b) there is no new requirement to file ITR by the second person who currently doesn’t file ITR due to their income being below threshold

If scruitiny comes & if u can explain then there is no issue

I had answered possible outcome of reporting Cash transaction never said u can not withdraw

As far as things are as per incometax law and explainable then fine

A withdrawal from a savings account is not, by itself, taxable income and does not create an ITR filing obligation. The key cash-withdrawal TDS rule is section 194N: a bank generally deducts TDS at 2% on cash withdrawals exceeding ₹1 crore in a financial year. For a person who has not filed the required returns for the preceding three assessment years, the lower threshold is ₹20 lakh, with 2% TDS on withdrawals above ₹20 lakh up to ₹1 crore and 5% above ₹1 crore. The rule applies to aggregate withdrawals from the relevant bank, not a daily limit; splitting withdrawals across days does not avoid it. On the stated figures, neither person’s proposed withdrawals should attract section 194N TDS, assuming no other withdrawals that take them across the applicable threshold.

  • There is no general ₹2 lakh-per-day ceiling on withdrawing one’s own cash from a bank account. Section 269ST’s ₹2 lakh restriction concerns receipt of cash, not a depositor withdrawing cash. Banks may still apply their own operational checks.
  • The person who does not file ITR is not required to file merely because they withdraw ₹5 lakh. ITR filing depends on income and other statutory conditions, not withdrawal amount.
  • Keep bank statements and, where relevant, records showing the source and intended use of the cash. A later cash payment or receipt may have separate restrictions; for example, section 269ST can restrict receiving ₹2 lakh or more in cash in specified circumstances.
  • Confirm each person’s aggregate cash withdrawals in the financial year and the other person’s return-filing history, since those facts determine whether section 194N applies.

Cash planning is therefore best checked alongside the bank’s transaction records and the applicable cash-payment rules. Manual tracking across accounts and financial years is difficult; automation can reduce repetitive work while leaving review and professional judgment in your control. At Jir AI we provide 2,000+ AI agents and 650+ integrations to streamline your practice’s day-to-day workload. WhatsApp us to explore how this can help your practice: https://wa.me/message/3HVOZ7HIY4ESC1

Correction first: Sec 269ST does not apply here. It restricts receiving cash of Rs 2 lakh or more from a person, and receipts from a banking company or post office are expressly excluded. Withdrawing your own money from your bank is not covered.

 

What does apply: TDS on cash withdrawal

• Up to 31.03.2026 (Sec 194N): 2% on withdrawals above Rs 1 crore a year. For a person who has not filed returns for the last 3 years: 2% above Rs 20 lakh and 5% above Rs 1 crore.

• From 01.04.2026 (Sec 393(3), Income-tax Act, 2025): 2% above Rs 1 crore. The non-filer rule has been dropped.

• The threshold is an annual aggregate across all accounts with that bank. Withdrawing Rs 2 lakh a day does not avoid it.

• TDS is not a cost: the non-filing parent can file a return and claim it as refund.

 

Reporting and scrutiny

• Large cash withdrawals are reported to the department and appear in AIS. Since the funds are already-taxed savings, keep a note of the purpose (medical, family function) and the bank statements.

• Whoever receives the cash from them for a single event must not receive Rs 2 lakh or more; that is where Sec 269ST bites (penalty equal to the amount, Sec 271DA).

• Prefer bank transfer to the payee wherever possible.

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