VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.194B: winnings from lottery, crossword puzzle, card games, gambling and betting, and the move to a per-transaction threshold
CBDT Circulars & InstructionsCuts both wayss.194Bs.194BAs.115BBs.115BBJs.58(4)s.201s.271C

Statutory position — s.194B: winnings from lottery, crossword puzzle, card games, gambling and betting, and the move to a per-transaction threshold

The lottery agent deducted tax on a five thousand rupee prize because my winnings for the year crossed ten thousand. Was he right, and does it depend on which year the prize was paid?

The lottery agent deducted tax on a five thousand rupee prize because my winnings for the year crossed ten thousand. Was he right, and does it depend on which year the prize was paid?

It depends entirely on the year. As s.194B stands from 1 April 2025, the threshold is ten thousand rupees in respect of a SINGLE TRANSACTION: the words 'or the aggregate of amounts' were substituted by 'in respect of a single transaction', and the words 'during the financial year' were omitted, both by Act No. 7 of 2025 with effect from 1 April 2025. Immediately before that the section worked on the amount or the aggregate of amounts exceeding ten thousand rupees during the financial year, so a payer had to add up a claimant's winnings across the year; and where the winning is wholly or partly in kind and the cash part is not enough to meet the tax, the payer must, before releasing the winnings, ensure that tax has been paid.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2025-04-01, reported as Income-tax Act, 1961, s.194B, as printed on the departmental page stamped Year 2026. It bears on section 194B, section 194BA, section 115BB, section 115BBJ, section 58(4), section 201, section 271C of the Income Tax Act 1961, in TDS Defaults and How Tax Law Is Read matters.

Still good law. Stated from the departmental page stamped Year 2026, which is the latest vintage of s.194B I could retrieve. No second page of the same vintage exists to corroborate it word for word, so the current text rests on one page — although the in-kind proviso is corroborated against the Year 2010 and Year 2012 pages, which print it identically. No Finance Act text was read this pass and the Act numbers in the footnotes were not matched to Finance Act names from an independent source. Anything applying an annual-aggregate threshold to a payment made on or after 1 April 2025, or a five thousand rupee threshold to a payment on or after 1 July 2010, is superseded by amendment.

Why it matters

This is a small-money section that generates a great deal of avoidable default, and the threshold has moved four ways: one thousand rupees when the section came in through the Finance Act, 1972; five thousand rupees substituted for one thousand by the Finance Act, 1986 with effect from 1 June 1986; ten thousand rupees substituted for five thousand by the Finance Act, 2010 with effect from 1 July 2010; then an annual-aggregate ten thousand; and now a per-single-transaction ten thousand from 1 April 2025. The direction of travel is worth noticing, because the aggregate rule and the single-transaction rule pull opposite ways: under the aggregate rule a run of small prizes could cross the threshold and require deduction on every later payment, while under the current rule each transaction stands alone. Getting this wrong in either direction is expensive — deducting where you need not invites a refund claim you cannot fund, and not deducting where you must exposes the payer to s.201 and s.271C. Two further points. The second proviso now takes online games out of s.194B on and after 1 April 2023, so a platform paying online-game winnings deducts under s.194BA and not under this section, and 'online game' takes its meaning from clause (iii) of the Explanation to s.115BBJ. And the section says 'at the rates in force', so the actual rate comes from the Finance Act rate schedule and not from s.194B itself; the substantive charge on this class of income is s.115BB.

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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Related

Other authorities on the same sections.