Examine the applicability and determine the amount of tax deduction at source as per the Income-tax Act, 1961 for the A.Y. 2026-27 in the following…

CA Intermediate · Taxation · MTP · September 2026
Examine the applicability and determine the amount of tax deduction at source as per the Income-tax Act, 1961 for the A.Y. 2026-27 in the following situations: (i) XYZ Ltd., having its registered office in Noida, organized its annual company function at its Gurgaon office. For this purpose, the company engaged Meta Pvt. Ltd. to arrange road transport for its employees from Noida to Gurgaon and back, for which a payment of ₹ 25,000 has to be made. Further, XYZ Ltd. also entered into a separate contract with Meta Pvt. Ltd. for providing catering services at the function, for ₹ 90,000. (ii) Suresh Health Solutions Ltd., a Third-Party Administrator (TPA), makes payments to various hospitals across India towards settling cashless medical insurance claims on behalf of insurance companies. During the financial year 2025-26, the total payment made by Suresh Health Ltd. to Care Hospital for cashless claims is ₹ 12,00,000.

Suggested Answer and Working Notes:

(i) Any person responsible for paying any sum i.e. ₹ 30,000 in a single payment or ₹ 1,00,000 in the aggregate during a financial year to a resident contractor for carrying out any work (including supply of labour for carrying out any work) in pursuance of a contract between the contractor and the contractee, tax has to be deducted at source u/s 194C at the time of payment of such sum or at the time of credit of such sum to the account of the contractor, whichever is earlier. In the present case, XYZ Ltd. has entered into separate contracts with Meta Pvt. Ltd. for arranging road transport and providing catering services, for ₹ 25,000 and ₹ 90,000, respectively. Both 'carriage of passengers' and 'catering' are expressly covered as "work" under section 194C. Even though the services are different, the aggregate payment to the contractor during the financial year is considered for the threshold limit. Hence, TDS@2% is applicable on ₹ 1,15,000, being the aggregate amount paid to Meta Pvt. Ltd. The amount of tax to be deducted by XYZ Ltd. would be ₹ 2,300. (ii) The payment by TPAs was made on behalf of insurance companies to hospitals for settlement of medical/insurance claims etc. under cashless claims which was on account of services rendered by hospitals to various patients. These services are primarily medical services and are liable to deduct tax at source under section 194J on all such payments to hospitals etc. as clarified by CBDT through Circular No. 8/2009 dated 24.11.2009. In the present case, Suresh Health Solutions Ltd. is required to deduct tax u/s 194J @10% on payment of ₹ 12 lakhs. The amount of tax to be deducted by Suresh Health Solutions Ltd. would be ₹ 1,20,000.

Topics: Paper 3A: Income Tax Laws

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