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Case lawCBDT Circulars & Instructions › Statutory position — s.165A of the Finance Act, 2016: the two per cent levy on e-commerce supply or services, the two crore threshold, the specified circumstances, and the 1 August 2024 cut-off
CBDT Circulars & InstructionsCuts both wayss.165As.165A(1)s.165A(2)s.165A(3)s.165A(4)s.165s.164s.166As.163(3)s.10(50)

Statutory position — s.165A of the Finance Act, 2016: the two per cent levy on e-commerce supply or services, the two crore threshold, the specified circumstances, and the 1 August 2024 cut-off

A foreign platform sold to Indian customers. Was it liable to the two per cent equalisation levy on its own receipts, what was the threshold, and when did that levy end?

A foreign platform sold to Indian customers. Was it liable to the two per cent equalisation levy on its own receipts, what was the threshold, and when did that levy end?

The two per cent levy is charged by section 165A of the Finance Act, 2016 — again, not by the Income-tax Act. It was inserted with effect from 1 April 2020 and charges two per cent of the consideration received or receivable by a NON-RESIDENT e-commerce operator from e-commerce supply or services made or provided or facilitated by it to a person resident in India, to a non-resident in the 'specified circumstances', or to a person who buys using an internet protocol address located in India. It is not charged where the operator has an Indian permanent establishment with which the supply is effectively connected, where the six per cent levy under section 165 is leviable, or where the operator's sales, turnover or gross receipts from e-commerce supply or services are less than TWO CRORE RUPEES during the previous year. Sub-section (4) ends the charge: it does not apply to consideration received or receivable on or after 1 AUGUST 2024.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2020-04-01, reported as Section 165A of the Finance Act, 2016, transcribed from incometaxindia.gov.in/w/section-165a (heading 'Charge of equalisation levy on e-commerce supply of services', Year: 2016, Act: Finance Acts); the section as originally inserted transcribed independently from section 153 of the Finance Act, 2020 at indiankanoon.org/doc/156332416/; the sub-section (3) restructuring transcribed from section 171 of the Finance Act, 2021 at indiankanoon.org/doc/101662731/. It bears on section 165A, section 165A(1), section 165A(2), section 165A(3), section 165A(4), section 165, section 164, section 166A, section 163(3), section 10(50) of the Income Tax Act 1961, in How Tax Law Is Read and Assessment & Scrutiny matters.

Still good law. The text is the current text of a spent charge: sub-sections (1) to (3) are stated as the departmental page prints them, and sub-sections (1), (2) and (3)(a) were independently confirmed word for word against the Finance Act 2020 provision that inserted them and sub-section (3)(b) against the Finance Act 2021 provision that added it. The 1 August 2024 cut-off in sub-section (4) is independently corroborated from the Income-tax Act side: section 10(50)(ii), as reproduced by the ITAT Mumbai on 30 December 2025 and re-read on a separate fragment query, confines the exemption to e-commerce supply or services 'made or provided or facilitated on or after the 1st day of April, 2020 but before the 1st day of August, 2024'. What I did not do: I could not verify from a government source which Finance Act inserted sub-section (4), and I did not read section 164 itself, so the definitions quoted here are as the amending Acts enacted them and may since have been further amended.

Why it matters

This levy is structurally different from the six per cent levy and the difference decides who is on the hook. There is no deduction at source: the non-resident operator itself is liable and pays quarterly under section 166A. That is why section 40(a)(ib) of the Income-tax Act, which disallows a payer's expenditure for failure to deduct or pay 'equalisation levy ... deductible', is written for the section 165 levy and does not reach this one. Three parts of section 165A are where the arguments are. First, the threshold in sub-section (2)(iii) is not a threshold on the Indian receipts alone: the words are 'sales, turnover or gross receipts, as the case may be, of the e-commerce operator from the e-commerce supply or services made or provided or facilitated as referred to in sub-section (1)', and sub-section (1) is itself India-facing, so the measure has to be read against sub-section (1) and not against the operator's global turnover. Second, clause (b) of sub-section (3), inserted retrospectively with effect from 1 April 2020 by the Finance Act 2021, sweeps in consideration for goods the operator does not own and services it merely facilitates, while carving out goods owned by, and services provided by, an Indian resident or an Indian permanent establishment where the sale or provision is effectively connected with that establishment. That clause is what makes a pure marketplace liable on the gross value it facilitates. Third, the cut-off is drafted by reference to consideration received or receivable on or after 1 August 2024, and that date does not fall at the end of a quarter, so it cuts the quarter itself in two: consideration received or receivable up to 31 July 2024 was chargeable and consideration received or receivable on or after 1 August 2024 was not. The quarter ending 30 June 2024 was chargeable in full and was payable by 7 July 2024; the quarter ending 30 September 2024 was chargeable only as to its July receipts, which were payable by 7 October 2024; and nothing thereafter was chargeable at all.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

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