/ 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.
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.
- Confirm buyer eligibility: turnover for immediately preceding FY exceeds INR 10 crore? If yes, you are 194Q liable.
- Identify sellers with > INR 50 lakh purchases in current FY: review purchase register. Track cumulative purchases per seller.
- Request PAN from sellers: without PAN, rate jumps to 5% under Section 206AA.
- 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.
- Deduct 0.1% at the first invoice that crosses INR 50 lakh cumulative, and continue on all subsequent purchases in that FY.
- Deposit TDS by 7th of the following month (last month: 30 April).
- File Form 26Q quarterly (Q1 by 31 July, Q2 by 31 October, Q3 by 31 January, Q4 by 31 May).
- 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.
Related reading