← US Incorporation

/ Blog · Section 206C(1H) TCS · Updated 2026-10-12

Section 206C(1H), seller-side TCS on goods.

Finance Act 2020 introduced Section 206C(1H) effective 1 October 2020: a seller with annual turnover above INR 10 crore in the preceding FY must collect 0.1% TCS on sale of goods to a buyer where aggregate sales exceed INR 50 lakh in the FY. In 2021, Section 194Q (buyer TDS) was introduced on the same transactions — the overlap rules are precise. Here's the full practitioner's guide.

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 206C(1H) core rule

Seller-side TCS.

Section 206C(1H) applies when:

  • Seller — any person whose aggregate turnover / receipts / sales in the immediately preceding FY exceeded INR 10 crore.
  • Buyer — any Indian resident buyer of goods.
  • Sales threshold — aggregate sales to that buyer in the current FY exceed INR 50 lakh.
  • TCS collected at 0.1% of the amount in excess of INR 50 lakh.

Timing of collection: at the time of receipt of the amount from the buyer.

PAN non-availability: if buyer does not provide PAN, Section 206CC kicks in — rate becomes 1% (not 5% unlike 194Q, note the asymmetry).

Exempt transactions: export of goods (outside India), sale to government, sale subject to TCS under other 206C sub-sections (e.g., 206C(1) on alcoholic liquor / scrap / minerals), sale where buyer deducts 194Q TDS (overlap rule).

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

Who collects / deducts.

Both sections cover the same transaction type (sale of goods). Both have INR 10 crore turnover thresholds and INR 50 lakh transaction thresholds. Both have 0.1% rate.

Rule: Section 194Q (buyer TDS) takes precedence. If both would apply, buyer deducts 194Q and seller does NOT collect 206C(1H).

Combinations:

BuyerSellerWho acts
Turnover > 10 crTurnover > 10 crBuyer deducts 194Q. Seller does not collect 206C(1H).
Turnover > 10 crTurnover < 10 crBuyer deducts 194Q. 206C(1H) does not apply.
Turnover < 10 crTurnover > 10 crSeller collects 206C(1H). 194Q does not apply.
Turnover < 10 crTurnover < 10 crNeither applies.

Written communication between buyer and seller at start of FY: 'We will deduct 194Q under Finance Act 2021' or 'We will collect 206C(1H)' prevents duplicate deduction + collection.

/ Compliance workflow for sellers

Quarterly cycle.

  1. Confirm seller eligibility: preceding FY turnover > INR 10 crore → 206C(1H) applicable.
  2. Identify buyers with > INR 50 lakh purchases from you: review sales register, track cumulative per buyer.
  3. Request buyer PAN: without PAN, rate is 1% under Section 206CC.
  4. Determine 194Q override: is the buyer 194Q-liable? Request written confirmation of buyer's turnover > INR 10 crore. If yes, buyer deducts 194Q; you do NOT collect 206C(1H).
  5. Collect 0.1% TCS at receipt on amounts above INR 50 lakh cumulative per buyer in FY.
  6. Deposit TCS by 7th of the following month.
  7. File Form 27EQ quarterly (Q1 by 15 July, Q2 by 15 October, Q3 by 15 January, Q4 by 15 May).
  8. Issue Form 27D to buyer within quarterly timeline. Buyer claims TCS credit on their ITR.

/ Common 206C(1H) compliance mistakes

Where sellers trip.

  • Double collection + deduction: not confirming buyer's 194Q applicability. Buyer deducts 194Q and seller also collects 206C(1H). Buyer refund requires manual process.
  • No PAN from buyer: rate jumps from 0.1% to 1% under Section 206CC.
  • Missing cumulative tracking: INR 50 lakh is cumulative per buyer per FY. Partial-year tracking causes under-collection.
  • 206C(1H) on exempt transactions: collecting on exports (exempt), government sales (exempt), or sales already under 206C(1) sub-sections (alcoholic liquor / scrap / minerals have specific TCS). Over-collection.
  • Timing error: 206C(1H) collection is at RECEIPT, not at invoice. If payment is deferred, TCS not collected till payment is received.
  • Not issuing Form 27D: buyer cannot claim TCS credit; relationship suffers; buyer may push back on TCS collection.
  • Not filing Form 27EQ quarterly: late-filing fee Section 234E at INR 200 per day; Section 271H penalty.

Last updated: 2026-10-12.

/ Ready when you are

Seller with turnover > INR 10 crore? Section 206C(1H) tracks every buyer.

Quarterly compliance: 194Q overlap analysis per buyer, cumulative sales tracking, Form 27EQ filing, Form 27D issuance. BQP annual engagement scopes the full TDS + TCS compliance stack for mid-size and large sellers.

FAQ

Common questions, answered.

What is Section 206C(1H)?
Seller-side TCS on sale of goods, introduced by Finance Act 2020 (effective 1 October 2020). Sellers with turnover above INR 10 crore in preceding FY must collect 0.1% TCS from buyer on sales above INR 50 lakh cumulative in current FY. TCS on amount above INR 50 lakh. Collected at time of receipt from buyer.
How does 206C(1H) interact with 194Q?
Both apply to the same sale-of-goods transaction. Rule: Section 194Q (buyer TDS) takes precedence. If buyer is 194Q-liable (turnover > INR 10 crore + cumulative purchases from you > INR 50 lakh), buyer deducts 194Q and seller does NOT collect 206C(1H). Request written confirmation from buyer of their turnover tier.
Is export of goods subject to Section 206C(1H)?
No - export is exempt from 206C(1H). Export is treated as outside India sale; TCS does not apply. Only domestic sale (buyer is Indian resident) triggers 206C(1H). For exports, standard GST export mechanics (LUT bond, zero-rated) apply.
What is the rate if buyer doesn't provide PAN?
Rate increases from 0.1% to 1% under Section 206CC (note: higher than 194Q's PAN-absent rate of 5%). Still request buyer PAN before sales cross the INR 50 lakh threshold - written PAN declaration from buyer is sufficient.
When is 206C(1H) TCS collected - at invoice or at receipt?
At RECEIPT. Unlike 194Q (which is at credit OR payment, whichever earlier), 206C(1H) is specifically at receipt. If buyer pays only part of the invoice, TCS applies on the amount received above INR 50 lakh. Full-invoice TCS collection at invoice stage is NOT correct.
Does BQP handle Section 206C(1H) compliance?
Yes - 206C(1H) applicability check, buyer PAN collection, 194Q vs 206C(1H) overlap analysis per buyer, written buyer declarations, TCS collection + deposit, Form 27EQ quarterly filing, Form 27D issuance. Co-ordinated with buyer-side 194Q where you also act as buyer in other transactions. WhatsApp +91 78018 87130.

Related resources from Bharat Quantum Prospera

Start here US incorporation intake wizard → Request a scoped quote → All tax & business calculators →
Core services US incorporation (Delaware / Wyoming) → SME IPO advisory → GIFT City / IFSC setup → Fund-raising advisory →
Deep guides NRI taxation complete guide → India-to-US flip → India-US DTAA → All 280+ guides →
About the firm CA Durgesh Chavda (founder) → Case studies → Press & media → Talk to a CA →