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Case lawCBDT Circulars & Instructions › Statutory position — s.194D: insurance commission, the threshold, and why the section states no rate
CBDT Circulars & InstructionsCuts both waysValidity unconfirmeds.194Ds.194DAs.194Gs.195

Statutory position — s.194D: insurance commission, the threshold, and why the section states no rate

The insurer deducted tax on my agency commission even though it was under twenty thousand rupees for the year. What is the s.194D threshold, and which year does my case fall in?

The insurer deducted tax on my agency commission even though it was under twenty thousand rupees for the year. What is the s.194D threshold, and which year does my case fall in?

Section 194D obliges any person paying a resident income by way of remuneration or reward, whether by way of commission or otherwise, for soliciting or procuring insurance business — including business relating to the continuance, renewal or revival of policies of insurance — to deduct at the rates in force, at credit or payment, whichever is earlier. The second proviso stops deduction where the amount of such income, or the aggregate of the amounts credited or paid or LIKELY to be credited or paid during the financial year to the payee, does not exceed twenty thousand rupees on the departmental page stamped Year 2026; the pages stamped Year 2020 and Year 2023 print fifteen thousand rupees, and the pages stamped Year 2012 and Year 2014 print twenty thousand rupees, substituted for five thousand by the Finance Act, 2010 with effect from 1 July 2010.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2010-07-01, reported as Income-tax Act, 1961, s.194D, as printed on the departmental page stamped Year 2026. It bears on section 194D, section 194DA, section 194G, section 195 of the Income Tax Act 1961, in TDS Defaults and How Tax Law Is Read matters.

Validity check could not be completed. The operative words of the section are stable across every vintage read this pass and are not in doubt. What is NOT established is the amending Act and commencement date for the current twenty thousand rupee threshold: the Year 2026 page carries no footnote list, and no 2024 or 2025 vintage page of s.194D was located, so the entry records the change as a difference between the Year 2023 and Year 2026 printed texts and attributes it to nothing. Nor is the reduction from twenty thousand to fifteen thousand, visible between the Year 2014 and Year 2020 pages, attributed to any Act. A practitioner acting on a threshold for a financial year between 2015-16 and 2025-26 must confirm it against the Finance Act for that year before advising.

Why it matters

Two things about this section trip people up. The first is the word 'likely'. The threshold proviso is not a wait-and-see rule: it disapplies deduction only where the amount credited or paid, or LIKELY to be credited or paid, during the financial year does not exceed the threshold. An insurer who knows from the agent's book that the year's commission will cross the figure cannot decline to deduct on the first small payment on the footing that the threshold has not yet been reached. The second is that s.194D states no rate at all. It says 'at the rates in force', which means Part II of the First Schedule to the relevant Finance Act — so a rate quoted from a commentary or from another section is worth nothing here and the practitioner must go to the Finance Act for the year. The threshold itself has gone up, down and up again — five thousand rupees, then twenty thousand from 1 July 2010, then fifteen thousand on the pages stamped 2020 and 2023, then twenty thousand again on the Year 2026 page — so the single most important step is to fix the financial year before quoting a figure. Note finally that the section is confined to a RESIDENT payee and to remuneration for soliciting or procuring insurance business; commission on the sale of lottery tickets has its own section in s.194G, and a payment under a life insurance policy is s.194DA and not this section.

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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