VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.166A of the Finance Act, 2016: the two per cent levy is paid by the e-commerce operator itself, quarterly, and is not deducted at source — with the 31 March quirk in the fourth quarter
CBDT Circulars & InstructionsCuts both wayss.166As.166s.165s.165As.165A(1)s.170s.171s.173s.40(a)(ib)

Statutory position — s.166A of the Finance Act, 2016: the two per cent levy is paid by the e-commerce operator itself, quarterly, and is not deducted at source — with the 31 March quirk in the fourth quarter

Who actually pays the two per cent equalisation levy, and by when? My client is being told the Indian customer should have withheld it.

Who actually pays the two per cent equalisation levy, and by when? My client is being told the Indian customer should have withheld it.

It is paid by the non-resident e-commerce operator itself, not withheld by the Indian customer. Section 166A of the Finance Act, 2016 — again, a Finance Act provision and not an Income-tax Act one — requires 'every e-commerce operator' to pay the levy referred to in section 165A(1) to the credit of the Central Government quarterly: by 7 July for the quarter ending 30 June, 7 October for the quarter ending 30 September, 7 January for the quarter ending 31 December, and by 31 MARCH for the quarter ending 31 March. That is the structural opposite of the six per cent levy on specified services, which section 166 makes the Indian payer deduct and pay over, and it is why the Income-tax Act's disallowance in section 40(a)(ib) is written for the six per cent levy and not for this one.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2020-04-01, reported as Section 166A of the Finance Act, 2016, transcribed with its Table from incometaxindia.gov.in/w/section-166a (heading 'Collection and recovery of equalisation levy on e-commerce supply or services', Year: 2016, Act: Finance Acts, footnote 'Inserted by the Finance Act, 2020 w.e.f. 1-4-2020'), and confirmed word for word against section 153(vii) of the Finance Act, 2020 at indiankanoon.org/doc/156332416/. It bears on section 166A, section 166, section 165, section 165A, section 165A(1), section 170, section 171, section 173, section 40(a)(ib) of the Income Tax Act 1961, in Demand, Recovery & Stay and Penalty matters.

Still good law. The section and its Table are confirmed on two independent sources — the departmental Finance Acts page stamped Year 2016 and the text of the Finance Act 2020 provision that inserted it — which agree word for word including the 31 March due date. The obligation is spent for consideration received or receivable on or after 1 August 2024 but governs every quarter from the first quarter of 2020-21 to consideration received or receivable before 1 August 2024 — which cuts the quarter ended 30 September 2024, so July 2024 consideration was still chargeable and was payable by 7 October 2024. What I did not do: I could not read sections 166, 170, 171 or 173 of the Finance Act 2016 in their current form and cannot say whether any of them has been amended since 2020; the penalty wording quoted here is the amending Act's, and a penalty order should be answered against the section itself.

Why it matters

The fourth-quarter due date is a trap. For the first three quarters the levy is payable on the seventh day of the month after the quarter ends; for the quarter ending 31 March it is payable ON 31 March, that is, on the last day of the quarter itself and before that quarter has finished. An operator that applies the seven-day pattern to the March quarter is late by definition, and section 170 of the Finance Act 2016 charges interest on delayed payment while section 171 provides a penalty. As inserted by the Finance Act 2020, section 171 carries a penalty for a section 166A default in these terms: 'in addition to the levy in accordance with the provisions of that section, or interest, if any, in accordance with the provisions of section 170, a penalty equal to the amount of equalisation levy that he failed to pay'. The other half of the point matters for Indian buyers: because there is no withholding obligation on a section 165A supply, an Indian customer of a foreign platform has no equalisation levy exposure of its own on that supply, and a demand raised against the Indian customer for the two per cent levy is raised against the wrong person. Conversely, on a section 165 specified-service payment the Indian payer IS the person who must deduct and pay, and the penalty for that default under section 171 is 'a penalty equal to the amount of equalisation levy that he failed to deduct'.

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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