Friday, April 19, 2024

TDS/TCS Compliance Calendar for the 4th Quarter of FY 2023-24 and FY 2024-25

TDS/TCS compliance, including payment and filing deadlines for the 4th quarter of FY 2023-24 and each quarter of FY 2024-25.

TDS Payment Due Dates

FY 2023-24: 4th Quarter (January - March 2024)

  • For Government Deductors: Due by 7th April 2024.
  • For Other Deductors: Due by 30th April 2024 for March deductions.

FY 2024-25 Payment Deadlines

  • For Government Deductors: 7th of the subsequent month for each month.
  • For Other Deductors: 7th of the subsequent month for each month except for March, which is due by 30th April 2025.

TDS/TCS Filing Due Dates

FY 2023-24: 4th Quarter (January - March 2024)

  • Forms 24Q, 26Q, 27Q: Due by 31st May 2024.
  • Form 27EQ: Due by 15th May 2024.

FY 2024-25: Quarterly Filing Deadlines

  • Q1 (April - June 2024):
    • Forms 24Q, 26Q, 27Q: 31st July 2024.
    • Form 27EQ: 15th July 2024.
  • Q2 (July - September 2024):
    • Forms 24Q, 26Q, 27Q: 31st October 2024.
    • Form 27EQ: 15th October 2024.
  • Q3 (October - December 2024):
    • Forms 24Q, 26Q, 27Q: 31st January 2025.
    • Form 27EQ: 15th January 2025.
  • Q4 (January - March 2025):
    • Forms 24Q, 26Q, 27Q: 31st May 2025.
    • Form 27EQ: 15th May 2025.

Penalties and Interest for Non-Compliance

  • Late Filing Fees: Rs. 200 per day until the return is filed, not exceeding the TDS amount.
  • Penalty under Section 234E: Charged at Rs. 200 per day of delay until the TDS/TCS is paid, capped at the TDS amount.
  • Penalty under Section 271H: A minimum of Rs. 10,000 and a maximum of Rs. 1,00,000 for incorrect filings or failure to file.

Interest for Late Payment

  • Section 201(1A)(i): Interest at 1% per month for failure to deduct TDS.
  • Section 201(1A)(ii): Interest at 1.5% per month from the date of deduction to the date of payment for delay in depositing TDS after deduction.

Note

  • All TDS/TCS returns must be filed electronically, and these returns must be verified either through a digital signature or via an Electronic Verification Code (EVC).

This detailed compliance calendar should assist in managing your TDS/TCS obligations systematically throughout the 4th quarter of FY 2023-24 and the entire FY 2024-25. 

TDS Payment and Filing Due Dates

Financial YearQuarterPeriodTDS Payment Due Date (Govt.)TDS Payment Due Date (Others)TDS/TCS Return Due Date (Forms 24Q, 26Q, 27Q)TCS Return Due Date (Form 27EQ)
2023-244th QuarterJan - Mar 20247th April 202430th April 202431st May 202415th May 2024
2024-251st QuarterApr - Jun 20247th July 20247th July 202431st July 202415th July 2024
2024-252nd QuarterJul - Sep 20247th October 20247th October 202431st October 202415th October 2024
2024-253rd QuarterOct - Dec 20247th January 20257th January 202531st January 202515th January 2025
2024-254th QuarterJan - Mar 20257th April 202530th April 202531st May 202515th May 2025

The impact of the Amendment to Section 43B of the Income Tax Act, 1961

"The devil is in the details."

This saying suggests that seemingly well-intentioned actions or provisions may contain hidden challenges or unintended consequences, much like the stringent provisions introduced by the amendment to Section 43B. While the aim is noble—to ensure timely payments to MSMEs—the intricate details and immediate implications may lead to unforeseen difficulties for businesses and the broader economy.

The amendment proposed to Section 43B of the Income Tax Act, 1961, targets the enhancement of payment timelines and financial stability for Micro and Small Enterprises (MSMEs). It mandates that businesses can only claim tax deductions for purchases or services from MSMEs upon actual payment, ensuring that MSMEs receive timely compensation.

Detailed Features of the Amendment

  1. Deduction Criteria: Businesses are permitted tax deductions for purchases or services from MSMEs only in the financial year during which the payments are actually made.
  2. Alignment with MSMED Act: Ensures compliance with payment timelines set under the Micro, Small and Medium Enterprises Development Act, which typically stipulate 15 to 45 days for settling invoices.
  3. Restriction on Provisos: Regular benefits under Section 43B, allowing deductions if payments are made by the tax filing deadline, will not apply to dues to MSMEs, emphasizing immediate settlement.

Financial Impact and Scenario Comparison

DescriptionScenario Without AmendmentScenario With Amendment
Net Profit Before Tax₹20,00,000₹20,00,000
Disallowance under Section 43B-₹3,80,00,000
Adjusted Taxable Income₹20,00,000₹4,00,00,000
Tax Liability (@ 30% + 4% cess)₹6,24,000₹1,39,77,600
Increase in Tax Liability-₹1,33,53,600

At-a-Glance Summary Before Concluding Remarks

  • Immediate Fiscal Pressure: Businesses may incur severe tax liabilities if payments to MSMEs are not cleared by the end of the fiscal year, irrespective of external factors like delayed receivables.
  • Ripple Effects: Large tax payments may restrict a business's ability to make future payments on time, potentially leading to a cycle of delayed payments and increased tax liabilities.
  • Potential Negative Impact on MSMEs: The amendment, while designed to protect MSMEs, might unintentionally cause businesses to delay payments further to manage their tax positions.
  • Broader Economic Implications: This change could have a cascading effect, where delayed payments and increased tax burdens propagate through the supply chain, potentially destabilizing multiple sectors.

Concluding Remarks

The amendment to Section 43B is crafted with the intention to support MSMEs by ensuring they are paid promptly. However, this regulation could introduce significant financial strains for businesses, potentially exacerbating the very issues it aims to resolve. The likely unintended consequences of increased tax burdens and delayed payments call for a reevaluation of the amendment or the introduction of additional supportive measures to truly benefit the MSME sector without destabilizing other businesses.