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Case lawCBDT Circulars & Instructions › Statutory position — s.194G: commission on the sale of lottery tickets, and the rate and threshold as they now stand
CBDT Circulars & InstructionsCuts both wayss.194Gs.197s.194B

Statutory position — s.194G: commission on the sale of lottery tickets, and the rate and threshold as they now stand

The lottery distributor deducted ten per cent from my agency commission. What is the correct rate and threshold under s.194G, and when did they change?

The lottery distributor deducted ten per cent from my agency commission. What is the correct rate and threshold under s.194G, and when did they change?

Not ten per cent, unless the payment is an old one. On the departmental page stamped Year 2025 the rate is TWO per cent and the threshold is TWENTY THOUSAND rupees: footnote 85 records that 'two' was substituted for 'Five' by Act No. 15 of 2024 with effect from 1 October 2024, and footnote 84 that 'twenty' was substituted for 'fifteen' by Act No. 7 of 2025 with effect from 1 April 2025, the earlier 'fifteen' itself having been substituted for 'one' by Act No. 28 of 2016 with effect from 1 June 2016. The section reaches any person paying, to a person who is or has been stocking, distributing, purchasing or selling lottery tickets, any income by way of commission, remuneration or prize by whatever name called on such tickets.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2025-04-01, reported as Income-tax Act, 1961, s.194G, as printed on the departmental page stamped Year 2025. It bears on section 194G, section 197, section 194B of the Income Tax Act 1961, in TDS Defaults and How Tax Law Is Read matters.

Still good law. The 1 June 2016 changes are attributed to Act No. 28 of 2016 on two independent departmental pages, and the 1 October 2024 and 1 April 2025 changes are attributed on the Year 2025 page, whose 1 April 2025 attribution to Act No. 7 of 2025 matches the attribution of the same-dated changes on the s.194B, s.194BB and s.194LA live pages. The current text nonetheless rests on that single Year 2025 page; no Year 2026 vintage of s.194G was located, so a 2025-26 amendment would not have been visible. No Finance Act text was read this pass. Anything stating a ten per cent rate or a one thousand rupee threshold is superseded by amendment for any payment made on or after 1 June 2016, and anything stating five per cent is superseded for a payment made on or after 1 October 2024.

Why it matters

Every figure in this section has moved twice in under a decade and the ten per cent that most people still quote has been wrong since 1 June 2016. The full ladder is: ten per cent on commission exceeding one thousand rupees from insertion by the Finance (No. 2) Act, 1991 with effect from 1 October 1991; five per cent on commission exceeding fifteen thousand rupees from 1 June 2016; two per cent from 1 October 2024; and the threshold up to twenty thousand rupees from 1 April 2025. Two structural points besides. First, the section is drawn by reference to the PAYEE's activity — a person who is or has been stocking, distributing, purchasing or selling lottery tickets — not by reference to the payer, so it catches a distributor paying a sub-agent as readily as a State paying a distributor, and the words 'or has been' keep a former agent within it. Second, the lower-deduction machinery that used to sit inside the section is gone: sub-sections (2) and (3), which let the Assessing Officer give a certificate for a lower rate or no deduction, were omitted by the Finance Act, 2003 with effect from 1 June 2003, so relief now has to be sought under the general s.197 route and not under s.194G itself. The Explanation deems a credit to a suspense account or any similarly named account to be a credit to the payee's account, which closes the obvious avoidance route.

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

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