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CBDT2022-06-16

CBDT Circular on s.194R TDS on Benefits and Perquisites — ₹20,000 Threshold and Gross-Up

CBDT Circular No. 12/2022

Clarifies TDS obligations under s.194R: 10% TDS on benefits/perquisites exceeding ₹20,000 per recipient per year. Deductor must gross-up if benefit is non-monetary.
Issued
2022-06-16
Effective from
2022-07-01
Act
Income Tax Act 1961 s.194R

What it says

Section 194R — basic obligation

Payer must deduct TDS at 10% on the value of any benefit or perquisite (whether convertible into money or not) provided to a resident, in connection with business or profession, exceeding ₹20,000 in aggregate per recipient per financial year.

₹20,000 aggregate threshold

TDS applies only when total benefits/perquisites to one recipient exceed ₹20,000 in the FY. Count from 1 April. Once the threshold is crossed, TDS applies from the next benefit payment onwards (cumulative tracking required).

Gross-up when TDS cannot be deducted from benefit

If the benefit is a physical item (gift hamper, car, etc.) and no cash payment exists to deduct TDS from, the payer must gross-up and pay TDS out of its own pocket. Circular provides the gross-up formula: TDS = (10/90) × benefit value.

What qualifies as a 'benefit or perquisite'

Free/subsidised goods or services, gift vouchers, use of car, holiday packages, free samples (other than for legitimate business promotion), cricket/club memberships provided as inducement for business.

Exclusion: genuine business samples

Free samples given in the ordinary course of business for product demonstration or promotion (not as a relationship reward) — excluded from s.194R. Circular para 8 provides guidance on the distinction.

Affected forms and returns

  • Form 26Q (quarterly TDS return)
  • Form 16A
  • GSTR-3B (if benefit is taxable supply)
⚠ VERIFY

Whether s.194R applies to conference/seminar expenses paid for dealers or channel partners — the circular addresses this; free trips/conferences for business promotion are likely covered. Verify the specific fact pattern with a CA before treating as exempt.

Primary source

CBDT Circular No. 12/2022 — issued by CBDT under Income Tax Act 1961 s.194R

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