PAN requirement for tax collection at source does not automatically trigger higher withholding absent statutory extension.
PAN under the withholding framework is mandated within the TDS chapter to compel registration and accurate reporting but does not, by its text, extend to the separate TCS chapter; consequently the higher withholding consequence for non furnishing or incorrect PAN in the TDS provisions does not automatically apply to TCS. The TCS lease and license collection rule fixes liability at time of debit or receipt and is silent on subleases, implying collection at the initial transaction absent further clarification. The TCS lower rate certificate procedure lacks a PAN requirement, creating inconsistency with TDS certificate rules and suggesting legislative or administrative harmonisation. (AI Summary)