VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.194-O: the e-commerce operator's rate fell to 0.1 per cent on 1 October 2024
CBDT Circulars & InstructionsCuts both waysValidity unconfirmeds.194-Os.194Qs.206C(1H)s.194J

Statutory position — s.194-O: the e-commerce operator's rate fell to 0.1 per cent on 1 October 2024

What rate does an e-commerce operator deduct now, when is a small seller outside the section, and does the Board's guidance bind me?

What rate does an e-commerce operator deduct now, when is a small seller outside the section, and does the Board's guidance bind me?

0.1 per cent of the gross amount of the sale or services, for anything on or after 1 October 2024; one per cent before that. No deduction is required where the e-commerce participant is an individual or HUF whose gross sales or services through the platform in the previous year do not exceed five lakh rupees and who has furnished PAN or Aadhaar to the operator. Guidelines issued by the Board under s.194-O(4) bind the income-tax authorities and the e-commerce operator alike.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2024-10-01, reported as Income-tax Act 1961, s.194-O; rate in sub-section (1) substituted for 'one' by Act No. 15 of 2024 w.e.f. 1 October 2024. It bears on section 194-O, section 194Q, section 206C(1H), section 194J of the Income Tax Act 1961, in TDS Defaults and How Tax Law Is Read matters.

Validity check could not be completed. Validity check could not be completed in the sense that no decision construing the section was located and none could therefore be checked. The statutory text was read on three current departmental pages with Year stamps of 2024 (No. 2), 2025 and 2026, and all three agree on the rate, the thresholds and the wording of every sub-section. The attribution of the rate change to Act No. 15 of 2024 with effect from 1 October 2024 comes from the department's own footnote and was not verified against the e-Gazette.

Why it matters

Section 194-O is drafted to override the rest of Part B of Chapter XVII: a transaction on which the operator has deducted, or which is exempt under sub-section (2), is not liable to tax deduction at source under any other provision of Chapter XVII. That override is about deduction only; the order of priority as between s.194-O, s.194Q and s.206C(1H) is worked out by s.194Q(5), by the provisos to s.206C(1H) and by CBDT Circular 13/2021, which this library already holds — not by s.194-O(3) standing alone. Two features matter in practice. Direct payment by the buyer to the seller is deemed by the Explanation to sub-section (1) to be an amount credited or paid by the operator, so a platform that never touches the money is still the deductor. And the carve-out in the proviso to sub-section (3) means that amounts the operator receives for hosting advertisements or for services unconnected with the sale keep their own character and stay outside the override.

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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