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/ Blog · Section 194Q TDS · Updated 2026-10-12

Section 194Q, buyer-side TDS on goods purchase.

Finance Act 2021 introduced Section 194Q effective 1 July 2021: a buyer with annual turnover above INR 10 crore in the preceding FY must deduct 0.1% TDS on purchase of goods from a seller where aggregate purchases exceed INR 50 lakh in the FY. The compliance workload is real, especially given overlap with seller-side Section 206C(1H) TCS. Here's the practitioner's map.

DC

Written by CA Durgesh Chavda

Chartered Accountant (ICAI) · Founder, Bharat Quantum Prospera · US incorporation, India-US DTAA, FEMA ODI, NRI taxation, cross-border structuring · LinkedIn

/ Section 194Q core rule

Buyer-side TDS.

Section 194Q applies when:

  • Buyer — any person (individual, HUF, firm, LLP, company, trust) whose aggregate turnover / receipts / sales in the immediately preceding FY exceeded INR 10 crore.
  • Seller — resident Indian seller of goods.
  • Purchase threshold — aggregate purchases from that seller in the current FY exceed INR 50 lakh.
  • TDS deducted at 0.1% of the amount in excess of INR 50 lakh.

Timing of deduction: at the time of credit of the amount to the seller's account OR at payment, whichever is earlier.

PAN non-availability: if seller does not provide PAN, Section 206AA kicks in — rate becomes 5% (or applicable rate, whichever higher).

Exempt transactions: purchase from government entity (Central Govt, State Govt, local authority), import of goods from outside India (buyer-side TDS on import not applicable; separate customs regime), transaction already subject to seller-side TCS under Section 206C(1H).

/ The 194Q vs 206C(1H) overlap

Who deducts what.

Finance Act 2021 added Section 194Q (buyer TDS) alongside existing Section 206C(1H) (seller TCS). Both apply to the same transaction — sale of goods. Rule: Section 194Q takes precedence where both would apply.

Overlap rules:

  • Buyer turnover > INR 10 crore AND Seller turnover > INR 10 crore AND purchases from seller > INR 50 lakh: Section 194Q applies (buyer deducts); Section 206C(1H) is not deducted by seller.
  • Buyer turnover > INR 10 crore but Seller turnover < INR 10 crore: Section 194Q applies; buyer deducts.
  • Buyer turnover < INR 10 crore but Seller turnover > INR 10 crore AND sales to this buyer > INR 50 lakh: Section 206C(1H) applies; seller deducts (collects as TCS).
  • Both buyer and seller turnover < INR 10 crore: neither 194Q nor 206C(1H) applies.

Practical consequence: buyers should proactively tell sellers 'we deduct 194Q, do not collect 206C(1H) TCS'. Written declaration helps prevent duplicate deduction / collection.

/ Compliance workflow

The quarterly rhythm.

  1. Confirm buyer eligibility: turnover for immediately preceding FY exceeds INR 10 crore? If yes, you are 194Q liable.
  2. Identify sellers with > INR 50 lakh purchases in current FY: review purchase register. Track cumulative purchases per seller.
  3. Request PAN from sellers: without PAN, rate jumps to 5% under Section 206AA.
  4. Confirm no Section 206C(1H) TCS applied by seller on your purchases. If seller has already applied TCS, you cannot also deduct 194Q TDS — coordinate.
  5. Deduct 0.1% at the first invoice that crosses INR 50 lakh cumulative, and continue on all subsequent purchases in that FY.
  6. Deposit TDS by 7th of the following month (last month: 30 April).
  7. File Form 26Q quarterly (Q1 by 31 July, Q2 by 31 October, Q3 by 31 January, Q4 by 31 May).
  8. Issue Form 16A to seller within quarterly timeline.

/ Common 194Q compliance mistakes

Where buyers trip.

  • Missing seller PAN: 0.1% becomes 5% under Section 206AA. On INR 1 crore invoice, that's INR 5 lakh vs INR 1,000. Chase PAN before invoice crosses threshold.
  • Double deduction / collection: seller collecting 206C(1H) TCS while buyer also deducting 194Q TDS. Overlap resolution: 194Q takes precedence; seller should not collect 206C(1H) when buyer deducts 194Q. Written communication prevents this.
  • Missing the INR 50 lakh threshold tracking: 194Q applies on amount above INR 50 lakh per seller per FY. Cumulative tracking essential; missing the threshold boundary means under-deduction + Section 201 interest.
  • Not filing Form 26Q quarterly: late filing fee under Section 234E at INR 200 per day. Section 271H penalty for non-filing or incorrect filing.
  • Not issuing Form 16A to seller: seller cannot claim TDS credit on their ITR without it. Vendor relationships suffer.
  • 194Q on exempt transactions: deducting on import purchases (customs regime applies, not 194Q), government supplier (exempt), or where seller is government. Over-deduction wastes TDS pool and creates reconciliation headaches.

Last updated: 2026-10-12.

/ Ready when you are

Company turnover > INR 10 crore? Section 194Q applies to your purchases.

Quarterly compliance: cumulative tracking per seller, deduction + deposit + Form 26Q + Form 16A. For mid-size and large Indian companies BQP runs this as standard annual engagement under one firm.

FAQ

Common questions, answered.

What is Section 194Q?
Buyer-side TDS introduced by Finance Act 2021 (effective 1 July 2021). Any buyer with aggregate turnover above INR 10 crore in the preceding FY must deduct 0.1% TDS on purchases from a seller where cumulative purchases exceed INR 50 lakh in the current FY. TDS on the amount above INR 50 lakh.
How does Section 194Q interact with Section 206C(1H)?
Both apply to the same sale-of-goods transaction. Rule: Section 194Q takes precedence. If buyer is 194Q-liable (turnover > INR 10 crore + cumulative purchases > INR 50 lakh), buyer deducts 194Q and seller does NOT collect 206C(1H) TCS. If buyer not 194Q-liable but seller is 206C(1H)-liable, seller collects TCS.
What is the rate if seller doesn't provide PAN under Section 194Q?
Rate jumps from 0.1% to 5% under Section 206AA. On a large invoice this is punitive. Always collect seller PAN before purchases cross the INR 50 lakh threshold. Written PAN declaration from seller is sufficient documentation.
Is import of goods subject to Section 194Q?
No - Section 194Q applies only to purchases from resident Indian sellers. Imports are governed by customs regime; buyer-side TDS on import is not applicable. For import payments, Section 195 (TDS on payments to non-residents) may apply depending on nature of payment, not Section 194Q.
When is Section 194Q TDS deposited and filed?
Deposited by 7th of the following month (last month: 30 April). Filed quarterly in Form 26Q (Q1 by 31 July, Q2 by 31 October, Q3 by 31 January, Q4 by 31 May). Form 16A issued to seller within quarterly timeline for seller to claim credit on their ITR.
Does BQP handle Section 194Q compliance?
Yes - 194Q applicability analysis, seller PAN collection + verification, cumulative purchase tracking per seller, TDS deduction + deposit, Form 26Q quarterly filing, Form 16A issuance, co-ordination with Section 206C(1H) overlap. Standard quarterly compliance for mid-size and large Indian companies. WhatsApp +91 78018 87130.

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