Complete TDS Compliance Checklist for CA Firms: Every Section, Every Deadline
TDS is one of the most complex compliance areas for Indian businesses. This checklist covers all major TDS sections, rates, thresholds, due dates for deposit, quarterly return filing, and common default types.
Why TDS Compliance Demands a Systematic Approach
TDS defaults — late deduction, late deposit, or non-filing of returns — attract interest at 1%-1.5% per month, penalties of ₹200/day under Section 234E for late filing, and in serious cases, prosecution under Section 276B. For CA firms managing payroll clients, contractor payments, or professional fee disbursements, tracking 20+ TDS sections across hundreds of clients is a genuine operational challenge. This checklist gives you the structure you need.
TDS Due Dates — Deposit to Government
| Deductor Type | Due Date |
|---|---|
| Government offices (challan + without challan) | Same day (without challan) or 7th of next month (with challan) |
| Non-government — April to February | 7th of the following month |
| Non-government — March | April 30 |
| TDS on immovable property purchase (Section 194-IA) | 30 days from end of month in which TDS deducted |
| TDS on rent (Section 194-IB) | 30 days from end of month in which TDS deducted |
TDS Return Filing Due Dates (Quarterly)
| Quarter | Period | Non-Govt. Due Date | Govt. Due Date |
|---|---|---|---|
| Q1 | Apr – Jun | July 31 | July 31 |
| Q2 | Jul – Sep | October 31 | October 31 |
| Q3 | Oct – Dec | January 31 | January 31 |
| Q4 | Jan – Mar | May 31 | May 15 |
Key TDS Sections — Rates and Thresholds
Section 192 — Salary
Rate: As per applicable tax slab. Threshold: Taxable income exceeds basic exemption limit. Employer computes total estimated salary income for the year and deducts TDS monthly. For employees opting for old regime, they must submit Form 12BB with investment declarations.
Section 194C — Payment to Contractors
Rate: 1% (individual/HUF), 2% (others). Threshold: Single payment exceeds ₹30,000 OR aggregate payments in the year exceed ₹1,00,000. Covers advertising agencies, printing contractors, transport, catering, and all contract work.
Section 194J — Professional / Technical Services
Rate: 10% for professional services (lawyers, CAs, doctors, consultants). 2% for technical services, call centre services, royalty on films. Threshold: ₹30,000 per year. Watch out: if your client pays a CA or lawyer fees, TDS u/s 194J applies.
Section 194-I — Rent
Rate: 10% for land, building, furniture; 2% for plant and machinery. Threshold: ₹2,40,000 per year per payee. This is a common area of default — many small businesses pay rent without deducting TDS.
Section 194-IA — Purchase of Immovable Property
Rate: 1% of consideration. Threshold: Property value exceeds ₹50 lakh. The buyer is responsible for TDS deduction. File Form 26QB (a challan-cum-statement) within 30 days of deduction.
Section 194Q — Purchase of Goods
Rate: 0.1%. Threshold: Aggregate purchase from a single seller exceeds ₹50 lakh in FY. Applies to buyers with turnover above ₹10 crore in preceding FY. Note: does NOT apply if seller is required to collect TCS under Section 206C(1H) on the same transaction.
Section 194D — Insurance Commission
Rate: 5% (individual/HUF), 10% (companies). Threshold: ₹15,000 per year.
Sections 194DA, 194EE, 194G, 194H
194DA (maturity of LIC policy exceeding threshold) — 5%; 194EE (NSS withdrawal) — 10%; 194G (lottery commission) — 5%; 194H (commission or brokerage) — 5%.
The Lower/Nil TDS Certificate Workflow
Clients with carry-forward losses, high refunds, or exempt income may be eligible for a lower or nil TDS certificate under Section 197. The application is made through TRACES (Form 13). The certificate must be submitted to the deductor. As a CA, track the validity period of all 197 certificates for your clients — they expire at year-end and must be renewed.
TDS Compliance Checklist for CA Firms
- ✅ Set up monthly reminders for TDS deposit (7th of each month)
- ✅ Set quarterly reminders for TDS return filing
- ✅ Verify TRACES acknowledgment for each TAN after filing
- ✅ Download Form 26AS for each client quarterly — check that deductors are depositing TDS on time
- ✅ Identify new payment categories each quarter — any new contractor, rent agreement, or professional engagement
- ✅ Check Section 194Q applicability for high-turnover buyer clients
- ✅ Renew Section 197 certificates before April 1 each year
- ✅ Reconcile TDS deducted in books vs TDS reflected in TRACES before ITR/tax audit