VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.194BA: winnings from online games, net winnings, and where s.194B stops
CBDT Circulars & InstructionsCuts both wayss.194BAs.194Bs.115BBJs.295

Statutory position — s.194BA: winnings from online games, net winnings, and where s.194B stops

The gaming platform deducted tax on my gross winnings from each game. Should it have been deducting on net winnings under s.194BA instead, and from when?

The gaming platform deducted tax on my gross winnings from each game. Should it have been deducting on net winnings under s.194BA instead, and from when?

Section 194BA was inserted by the Finance Act, 2023 with effect from 1 April 2023 and, notwithstanding anything contained in any other provision of the Act, requires a person paying income by way of winnings from any online game during the financial year to deduct tax on the NET WINNINGS in the payee's user account, computed in the manner prescribed, at the end of the financial year at the rates in force. Where there is a withdrawal from the user account during the year, deduction is at the time of withdrawal on the net winnings comprised in that withdrawal, as well as on the remaining net winnings in the user account computed in the prescribed manner at the end of the year — and from the same date the second proviso to s.194B takes online-game winnings out of s.194B altogether.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2023-04-01, reported as Income-tax Act, 1961, s.194BA, as printed on the departmental pages stamped Year 2023 and Year 2024 (No. 2). It bears on section 194BA, section 194B, section 115BBJ, section 295 of the Income Tax Act 1961, in TDS Defaults, Crypto & Virtual Digital Assets and How Tax Law Is Read matters.

Still good law. Two departmental pages of different vintages print the section identically and attribute it to the same Act and date, which is the strongest evidence available this pass that no later amendment has displaced it. The most recent vintage I could retrieve for this section is Year 2024 (No. 2); I did NOT find a Year 2025 or Year 2026 page for s.194BA, so an amendment made in 2025 or 2026 would not have been visible to me. No Finance Act text was read this pass. The prescribed manner of computing net winnings was NOT retrieved and nothing above states it.

Why it matters

The whole design of this section is that it does not tax a gross prize. Deduction is on net winnings in the user account, and the unit of account is the account and the financial year, not the individual game. That is why the section has to open with a non obstante clause and why s.194B had to be shut off for online games on the same date: a platform still deducting on each gross win is over-withholding, and a platform deducting nothing until year end is under-withholding if there have been withdrawals. Three structural points that carry weight in a dispute. First, the section contains no threshold on its face — no ten thousand rupee figure, nothing — so any de minimis relief a platform is applying is coming from somewhere other than the section. Second, sub-section (2) puts the same in-kind burden on the payer as s.194B does, in the same words: where the net winnings are wholly in kind, or partly in cash and partly in kind and the cash is not enough to meet the tax on the whole, the payer must before releasing the winnings ensure that tax has been paid. Third, sub-sections (3) and (4) give the Board a power to issue guidelines to remove difficulties, and provide that every such guideline, once laid before each House of Parliament, is BINDING on the income-tax authorities and on the person liable to deduct — a materially stronger status than an ordinary circular, and the source of the guidance this library already carries as Circular No. 5 of 2023.

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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