Great questions! You're on the right track regarding Section 194M, and I’ll break down both your queries with the applicable reasoning based on current rules:
✅ Quick Background on Section 194M:
- Applicable to Individuals or HUFs (non-audit cases) making payments to resident contractors, professionals, or for commission / brokerage, exceeding ₹50 lakhs in a financial year.
- TDS is deductible on the entire amount (not just the excess over ₹50L) once the threshold is crossed.
- From 1st October 2024, the TDS rate is reduced from 5% to 2% (as per the Union Budget 2024 amendment).
💡 Your Scenario:
Particulars | Amount | Date |
1st Payment | ₹10L | Sep 2024 |
2nd Payment | ₹70L | 30 Dec 2024 |
Total till now | ₹80L | Threshold exceeded |
3rd Payment | ₹20L | March 2025 |
📌 Q1: TDS Rate – Is 2% Applicable on Entire ₹80L in December?
✅ Yes, correct.
Since the liability to deduct TDS arises only when the total payment crosses ₹50L, and in your case, it happens on 30th Dec 2024, the applicable TDS rate is the one in force on that date.
- Hence, TDS = ₹80L × 2% = ₹1.6L
- You do not need to apply 5% on the ₹10L paid earlier, as TDS was not required at that time (threshold not crossed yet).
📌 Q2: How to show two payment dates in Form 26QD when only one payment date field is allowed?
This is a common issue with Form 26QD.
- The form only accepts one "Date of Payment/Credit", so you need to enter the date when the threshold was crossed and TDS becomes applicable — in your case, 30th Dec 2024.
➡️ Steps to file Form 26QD in this case:
- Total payment: ₹80,00,000
- TDS deducted: ₹1,60,000
- Date of payment/credit: 30-Dec-2024
- Date of TDS deduction: 30-Dec-2024
- Payment type: Contractual (as applicable)
📝 Note: While the first ₹10L was paid in September, it did not attract TDS as the threshold wasn’t breached then. Once the threshold is crossed in December, TDS applies retrospectively on the entire ₹80L paid during the year, and you report it as a single consolidated transaction as per Form 26QD limitations.
📌 For 3rd Payment of ₹20L in March 2025:
You will have to file another Form 26QD for that payment:
- Amount paid: ₹20L
- TDS: ₹40,000 (2%)
- Date of payment/credit: March 2025
- Date of deduction: Same as above
✅ Summary:
Payment Date | Amount Paid | TDS Deduction Date | TDS Rate | TDS Amount | Form |
Sep 2024 | ₹10L | Dec 30, 2024 | 2% | ₹1.6L on ₹80L | 26QD (Dec) |
Dec 2024 | ₹70L | Dec 30, 2024 | 2% | Part of ₹1.6L | 26QD (same) |
Mar 2025 | ₹20L | Mar 2025 | 2% | ₹40K | 26QD (Mar) |