Query on Recent TCS Applicability Amendment – Sale of High-Value Shoes

[Ramanathan Seshan]

Dear Experts,

Could someone please clarify the recent amendment regarding TCS applicability on the sale of shoes? Specifically, is TCS to be charged only if the value of a single pair of shoes exceeds ₹10 lakhs, or is it based on the total value per invoice?

Regards,

S Ram

[YAGAY and SUN]

Please share relevant Notification/Circulars/Laws to revert on abovementioned query.

[Ramanathan Seshan]

Dear Yagay and sun-sir,

Please find the egazette published on 22 April 2025

https://egazette.gov.in/(S(zbtssh5l3nr0ng4avgkupzas))/SearchMinistry.aspx?id=239869

Notification No. 36/2025, New Delhi, the 22nd April, 2025

Regards,

S ram

[Jayachandra S And Co]

Dear Sir, i believe based on the language in the notification, it is for a pair of shoes exceeding Rs. 10lakh and not the invoice value as the directive is towards luxury items. However, a CBDT clarification is required on this to avoid different interpretations. 

[YAGAY and SUN]

Thank you for sharing Notification No. 36/2025 dated 22nd April 2025, issued by the Ministry of Finance (CBDT) under Section 206C(1F)(ii) of the Income-tax Act, 1961.

🔍 Key Provision:

The notification mandates Tax Collected at Source (TCS) on the sale of specified luxury/high-value goods where the value exceeds ₹10 lakh.

✅ Specific to Your Query:

"Is TCS to be charged if the value of a single pair of shoes exceeds ₹10 lakhs, or is it based on the total value per invoice?"

📌 Clarification Based on Notification:

The notification uses the wording:

"any pair of shoes of the value exceeding ten lakh rupees"

This clearly indicates that:

• The TCS applicability is on the value of each individual item, not the total value of the invoice.
• Therefore, TCS is required only if a single pair of shoes is sold for more than ₹10,00,000.

✅ Example Scenarios:

Scenario	TCS Applicable?	Reason
1 pair of shoes worth ₹11,00,000	✅ Yes	Value of a single pair exceeds ₹10 lakh
5 pairs of shoes worth ₹2,00,000 each (Total: ₹10 lakh)	❌ No	None of the individual items exceed ₹10 lakh
1 pair of shoes worth ₹9,90,000 + 1 bag worth ₹11,00,000	✅ Yes (on bag only)	TCS applies only to items individually valued over ₹10 lakh

🧾 Additional Notes:

• The seller will need to collect TCS at 0.1% (likely rate unless changed) from the buyer at the time of sale, provided the value of each specified item exceeds ₹10 lakh.
• TCS should be deposited with the government and reflected in the buyer’s Form 26AS.

Conclusion:

TCS under Notification No. 36/2025 is applicable only when the value of a single item (e.g., a pair of shoes) exceeds ₹10,00,000, not on cumulative invoice value. So, if each pair of shoes is below ₹10 lakh, TCS is not applicable, regardless of total invoice value.

Disclaimer - This revert is not an Legal Opinion. For further clarification you may seek profession advice/ an Opinion from CA/Tax Consultant and or clarification from Income Tax Authorities.

[Ramanathan Seshan]

Dear Samarth-sir, Yagay sir

Thank you for your valuable inputs.

Regards,

S Ram

AI Summary

TCS on High-Value Goods applies to individual luxury items exceeding a specified threshold, not invoice totals.
TCS under the notification applies to specified luxury/high value goods when the value of an individual item exceeds the prescribed threshold; it is triggered by the value of each specified item at the time of sale rather than by the cumulative invoice value. Sellers must collect TCS at the prescribed rate, remit it to the government, and report it in the buyer's tax records.