VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.194-IC: ten per cent on the cash consideration under a specified agreement, with no threshold at all, and the one section in this family that does not disapply s.203A
CBDT Circulars & InstructionsCuts both waysValidity unconfirmeds.194-ICs.194-IAs.45(5A)s.203A

Statutory position — s.194-IC: ten per cent on the cash consideration under a specified agreement, with no threshold at all, and the one section in this family that does not disapply s.203A

I am the developer under a joint development agreement with an individual landowner. I am giving him constructed area plus some cash. What do I have to deduct, on what, and do I need a TAN?

I am the developer under a joint development agreement with an individual landowner. I am giving him constructed area plus some cash. What do I have to deduct, on what, and do I need a TAN?

You deduct ten per cent, but only on the monetary consideration. Section 194-IC applies notwithstanding section 194-IA to any person responsible for paying a resident any sum by way of consideration, 'not being consideration in kind', under the agreement referred to in section 45(5A), at the time of credit to the payee's account or at the time of payment, whichever is earlier — and unlike sections 194-IA, 194-IB and 194M it contains no provision disapplying section 203A, so the deductor needs a TAN and files an ordinary quarterly return.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2017-04-01, reported as Income-tax Act, 1961, s.194-IC, as printed identically on the departmental pages stamped Year: 2026, Year: 2025, Year: 2021, Year: 2020 and Year: 2017. It bears on section 194-IC, section 194-IA, section 45(5A), section 203A of the Income Tax Act 1961, in TDS Defaults, Capital Gains and House Property matters.

Validity check could not be completed. Validity check could not be completed. The Year 2021 and Year 2026 departmental pages print the section identically, which shows it was not amended between those two stamps, but neither page carries any amendment footnote against the operative words, so the section's commencement was not dated from any source read this pass and no statement is made about it; the 'decided_on' value of 1 April 2017 is a labelled placeholder taken from the earliest departmental year-stamp on which the identical text appears (Year: 2017) and is not a verified commencement date. No Finance Act text was retrieved and no citator check was run. The conditions in section 45(5A) on which the section depends were not retrieved and are not stated: every departmental page for section 45 that could be reached was archived and printed no sub-section (5A). The section 203A point is an inference from the statutory text and the departmental Form references, not a holding, and should be treated as such.

Why it matters

Three features of this short section decide most of the disputes. First, there is no threshold whatever. Sections 194-IA, 194-IB and 194M each carry a monetary floor; section 194-IC does not, so a single rupee of cash consideration under a specified agreement attracts deduction. Second, the exclusion of consideration in kind means the constructed area — usually the bulk of what the landowner receives — is outside the section entirely, and a developer who deducts on the value of the built-up share is deducting on something the section does not reach. Third, and this is the trap that produces section 201 demands against developers who thought they were in the same regime as a flat buyer, section 194-IC does NOT disapply section 203A. The departmental page's own note for this section refers to Forms 16A, 24G, 26B, 26Q and 27A — the ordinary TDS return and certificate — and not to any challan-cum-statement, whereas the notes for sections 194-IA, 194-IB and 194M refer respectively to Forms 26QB and 16B, 26QC and 16C, and 26QD and 16D. A developer who pays cash under a joint development agreement without a TAN is exposed on section 203A as well as on the deduction. The opening words also matter: 'Notwithstanding anything contained in section 194-IA' resolves the overlap in favour of this section where a specified agreement is in play, so the one per cent charge does not apply to the same payment.

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

Not yet CA-verified. This entry was found through the sources listed under the Sources tab, and the summary reflects what those sources say. Nobody has yet read the full judgment and signed it off. Check the source before relying on it.

Read aloud by your device. Press again to stop.

Related

Other authorities on the same sections.