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TDS Section 194-Q vs 194-O: the buyer-side trap most Indian SMEs missed in Q4 FY26

By Aniruddh Bhatia & Mansi Khurana · · TDS

Section 194-Q (buyer-side TDS on purchase of goods) and Section 194-O (e-commerce operator TDS) were both introduced in Finance Act 2021. The operational overlap between them has been a chronic source of compliance error. Q4 FY26 reconciliations across our SME client base show two patterns: buyers double-deducting and buyers omitting 194-Q on direct purchases.

Section 194-Q applies to buyers whose total turnover in the preceding financial year exceeded 10 crore. On purchase of goods from a resident seller where aggregate purchase value exceeds 50 lakh in the financial year, the buyer must deduct TDS at 0.1%.

Section 194-O applies to e-commerce operators on the gross amount of sales facilitated through the platform, at 1%. CBDT Circular 13 of 2021 clarifies that Section 194-O takes precedence over 194-Q where both apply.

KAMRIT Direct Tax desk runs a 194-Q vs 194-O reconciliation as part of the year-end TDS closing engagement.

Author - Aniruddh Bhatia, Associate Partner, Direct Tax
Co-Author - Mansi Khurana, Associate Partner, Indirect Tax

Aniruddh Bhatia

Associate Partner, Direct Tax

Aniruddh is an Associate Partner leading the direct tax desk at KAMRIT. He is a Chartered Accountant with 11 years of experience in income tax, TDS, advance tax, scrutiny assessments, and tax audit under Section 44AB. He has represented over 80 Indian businesses in assessment and appellate proceedings.

aniruddh.bhatia@kamrit.com

Mansi Khurana

Associate Partner, Indirect Tax

Mansi leads the GST and indirect tax practice at KAMRIT. She is a Chartered Accountant and Cost Accountant with 12 years of experience in GST registration, returns, refunds, ITC management, e-invoicing, and GST audit. She has recovered ₹14 crore in cumulative GST refunds for KAMRIT exporters.

mansi.khurana@kamrit.com

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