TCS on Sales of any Goods on receipt basis and Accounting Treatment

     Section 206C (1H] has been made effective from 1^st October 2020 and state that:

1. A Seller of Goods is liable to collect TCS from Buyer on Sale of any goods;
2. Turnover(Turnover as per Tax Audit Report) of seller is more than ₹ 10 Crores in preceding financial year;
3. TCS to be collected if the Value/Aggregate Value received(Include GST and collected on advance payments) for Goods from a buyer is more than ₹ 50 Lakhs in a financial year;
4. TCS to be collected on [ Total Sale Value received – ₹ 50 Lakhs];
5. Rate of TCS is 0.1% [0.075% up to 31.3.21] if PAN of buyer is available [1% if PAN not Available].

• Not applicable [Excluded Transactions] :
  1.  If, Turnover (Turnover as per Tax Audit Report) of seller is less than ₹ 10 Crores in preceding financial year; TCS is not required to be collected by Seller.
  2. Sale of immovable property,
  3. Exports,
  4. sale to Government and local authority
  5. Sale of services.
  6. where TCS (e.g. sale of liquor) is collected or TDS is deducted (e.g. works contracts)
  7.  Recovery/collection amount (not sales amount) less than 50, 00,000/- in a financial year. Sale may belong to any period.
  8.  Since the effective date is 01.10.2020- No TCS on earlier recovery (till 30.09.2020) is required. Even it is exceeding ₹ 50,00,000/-

• How and when to charge TCS from buyer and accounting treatment :

Alternative-1: The TCS can be collected by charging through Debit Note cum Receipt at the time of every receipt:

But in that case, a specific series of debit note number may need to be used to make sure that these debit notes do not create issues in GST compliance.

Accounting Entry for amount received ₹ 20,00,000/- (Debit Note cum Receipt]:

Bank A/c -----------Debit----------------- ₹ 20,00,000/-

Buyer’s A/c --------Debit----------------- Rs       1,500/-

      To Buyer’s A/c -------------------------------------------₹ 20,00,000/-

       To TCS on Sales of any Goods----------------------Rs.       1,500/-

Alternative-2: The TCS can be collected by charging through Debit Note at the time of end of the month: [Simple]

But in that case, a specific series of debit note number may need to be used to make sure that these debit notes do not create issues in GST compliance.

Accounting Entry for amount received during the month ₹ 1,00,00,000/- - Debit Note:

Buyer’s A/c --------Debit----------------- Rs       7,500/-

[For all receipt of the month]

       To TCS on Sales of any Goods----------------------Rs.       7,500/-

Alternative-3 : The TCS can be collected by charging through invoice: [Reconciliation Required]

Both buyer and seller need to do accounting as receivable and payable for these amounts. If the payment is being made in next financial year, TCS obligation may not be applicable on seller (due to turnover threshold ₹ 50,00,000) or may not be applicable on buyer due to not making payments breaching ‘collection’ threshold in that financial year. In those case, one need to keep track and write off and reconcile it with the liability.

Accounting Entry for TCS can be collected by charging through invoice for Goods sold ₹ 15,00,000/-:

Buyer’s A/c --------Debit----------------- Rs       15,76,181.25/-

To Sales A/c --------------------------------------------- ₹ 15,00,00/-

 [Value of Goods including freight]

To  IGST A/c ----------------------------------------------Rs.    75,000/-

[Gst @5%]

          To TCS on Sales of any Goods----------------------Rs.      1,181.25/-

                   [.075% on Value goods plus IGST]

At the end of the month, reconcile the amount received and make the payment toward TCS on sales of any goods:

  TCS on Sales of any Goods------Debit----------------Rs. XXXXXXXX/-

          To Bank  A/c---------------------------------------------------------Rs.xxxxxx/-

At the end of the Financial Year, reconcile the amount received and TCS paid for each party and reverse the balance of TCS on Sale of any Goods:

TCS on Sales of any Goods------Debit----------------Rs. XXXXXXXX/-

[ Balance after making the TCS payment on Received basis]

         To  Buyer’s A/c ---------------------------------------------- Rs       xxxxxxx/-