VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.194-IB and s.194M: the once-a-year deduction on rent, the cap that operates only under s.206AA, the gateway that keeps most individuals out of s.194M, and why neither needs a TAN
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Statutory position — s.194-IB and s.194M: the once-a-year deduction on rent, the cap that operates only under s.206AA, the gateway that keeps most individuals out of s.194M, and why neither needs a TAN

I am an individual paying Rs 70,000 a month rent, and separately I have paid an interior contractor Rs 62 lakh for my own house. When exactly do I deduct, how much, and do I need a TAN?

I am an individual paying Rs 70,000 a month rent, and separately I have paid an interior contractor Rs 62 lakh for my own house. When exactly do I deduct, how much, and do I need a TAN?

Under section 194-IB you deduct once, not monthly: the tax is deducted at the time of credit of rent for the last month of the previous year, or the last month of the tenancy if you vacate during the year, or at the time of payment of that rent, whichever is earlier, and the rate is two per cent of the income by way of rent, substituted for five per cent with effect from 1 October 2024. Under section 194M you deduct two per cent, again substituted for five per cent from the same date, but only if you are not a person required to deduct under section 194C, 194H or 194J, and only if the sum or aggregate of sums credited or paid to that resident during the financial year exceeds fifty lakh rupees. Neither section requires a TAN: section 194-IB(3) and section 194M(2) each disapply section 203A.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2024-10-01, reported as Income-tax Act, 1961, ss.194-IB and 194M, as they stand after the rate in each was reduced from five per cent to two per cent with effect from 1 October 2024. It bears on section 194-IB, section 194-IB(1), section 194-IB(2), section 194-IB(3), section 194-IB(4), section 194M, section 194M(1), section 194M(2), section 203A, section 206AA, section 206AB, section 194C, section 194H, section 194J, section 194-I, section 194D of the Income Tax Act 1961, in TDS Defaults and House Property matters.

Still good law. The two per cent rate for section 194-IB is corroborated on two departmental pages that footnote it to the same Act and the same date: https://incometaxindia.gov.in/w/section-194-ib-2 (Year: 2026), footnote 42, 'Sub. for "five" by Act No. 15 of 2024, w.e.f. 1-10-2024', and https://incometaxindia.gov.in/w/section-194ib-6 (Year: 2024 (No. 2)), footnote 97, 'Sub. for "five" by the Act No. 15 of 2024, w.e.f. 1-10-2024'. The identical change to section 194M is corroborated on two current pages, https://incometaxindia.gov.in/w/section-194m-8 (Year: 2026), footnote 47, and /w/section-194m-7 (Year: 2025), footnote 97-98, in the same terms. Every other page for either section reachable this pass is stamped 2024 (No. 1) or earlier and prints five per cent, which is the correct negative control. The gateway, the thresholds, the once-a-year timing rule, the section 206AA cap and the section 203A disapplications are printed identically across every version read. No Finance Act text was retrieved and no citator check was run, so a later amendment cannot be excluded and the Act is recorded by its number as the department prints it, not by a popular name. Anything applying five per cent under either section to a credit or payment on or after 1 October 2024 is superseded by amendment; and any statement that section 194-IB(4) caps the deduction generally, rather than only in a section 206AA case, is wrong on the text as printed.

Why it matters

These are the two provisions that make a private individual a deductor without his ever having filed a TDS return, and the machinery in them is unlike the rest of Chapter XVII-B. Section 194-IB deducts once a year, on the last month's rent, which means the entire year's tax is taken out of one month's payment; a tenant who pays the full rent every month and then discovers the obligation in March has nothing left to deduct from. That is what sub-section (4) is for — and it is narrower than it is usually described. It caps the deduction at the last month's rent ONLY 'in a case where the tax is required to be deducted as per the provisions of section 206AA', that is, where the landlord has furnished no PAN and the rate is therefore twenty per cent. It is not a general cap on the deduction. Its history is worth knowing because it moved twice: the words 'or section 206AB' were inserted in sub-section (4) with effect from 1 July 2021 and omitted again with effect from 1 April 2022, so a deduction in the intervening period fell under a differently worded cap. On section 194M the gateway is what keeps most people out and catches a few badly: it applies only to an individual or Hindu undivided family 'other than those who are required to deduct income-tax as per the provisions of section 194C, section 194H or section 194J' — so a proprietor whose accounts were audited in the preceding year is outside section 194M and inside the ordinary sections, at the ordinary rates and with a TAN. The fifty lakh rupee test is on the aggregate for the financial year to that resident, so a series of payments to the same contractor is added up.

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