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Microlesson · 5-min read

Inadmissible Deductions [Section 40] — TDS non-compliance and other disallowances

## Inadmissible Deductions — Section 40

Section 40 lists payments that are disallowed even if otherwise allowable under Sections 30–37, mostly to enforce TDS compliance.

### A. Disallowance for non-compliance with TDS — 40(a)(i) / 40(a)(ia)

Trigger: TDS was deductible but not deducted in the relevant PY (RPY), OR was deducted but not remitted by the due date u/s 139(1).

PayeeSectionExtent disallowed
Non-resident (non-corporate or foreign company)40(a)(i)100% of the payment
Any resident payee40(a)(ia)30% of the payment
  • For non-residents, 40(a)(i) covers interest, royalty, FTS, or other sums chargeable to tax.
  • Payments made outside India are always 100% disallowed.
  • RPY = the previous year in which the expenditure is incurred.

Subsequent allowance: The disallowed amount is allowed later

  • If TDS was deducted but not remitted in RPY → allowed in the year of actual remittance.
  • If TDS was not deducted in RPY → allowed in the year of actual deduction and remittance.
  • In both cases the 139(1) due date is irrelevant for the later allowance.

Assumed compliance: The payer is not treated as assessee-in-default u/s 201(1) if the payee (i) files a return u/s 139, (ii) includes the receipt in income, and (iii) pays tax on it — and the payer obtains an accountant's certificate. TDS is then deemed deducted/remitted in the year the payee files the return (deduction allowed in subsequent PYs). Interest u/s 201(1A) still runs up to the deemed date of deduction.

### B. Taxes on income — 40(a)(ii)

Any tax on profits/gains of business or profession, including surcharge and cess, is disallowed (e.g., income tax, surcharge, education cess).

### C. Salaries paid outside India / to non-residents — 40(a)(iii)

Disallowed if TDS is not deducted, or deducted but not deposited per Chapter XVII-B.

### D. Contributions to employee welfare funds — 40(a)(iv)

Contribution to PF or other funds is disallowed if the assessee has not made effective arrangements to deduct TDS on taxable 'Salaries' payments made out of the fund.

### E. Tax on non-monetary perquisites — 40(a)(v)

Tax paid by the employer on non-monetary perquisites on behalf of employees is disallowed. Correspondingly, the benefit is exempt in the employee's hands u/s 10(10CC).

Worked example

### Example 1

30% vs 100% disallowance.

A business pays ₹5,00,000 contract charges to a resident but fails to deduct TDS in the year of expenditure.

  • Disallowance u/s 40(a)(ia) = 30% × ₹5,00,000 = ₹1,50,000 disallowed this year.
  • When TDS is later deducted and remitted, the ₹1,50,000 is allowed in that subsequent year.

Contrast: if the same payment were made to a non-resident with no TDS, 40(a)(i) disallows 100% = ₹5,00,000.

### Example 2

Assumed compliance.

Payer fails to deduct TDS on a ₹3,00,000 fee to a resident. The payee files his return u/s 139, includes the ₹3,00,000, and pays tax. The payer obtains an accountant's certificate.

→ Payer is not an assessee-in-default; TDS is deemed deducted/remitted in the year the payee filed — the ₹90,000 (30%) is allowed as a deduction in that subsequent PY. Interest u/s 201(1A) runs up to the deemed date of deduction.

⚠️ Common exam mistakes

  • Applying 30% disallowance to a non-resident payee — non-residents attract 100% disallowance under 40(a)(i).
  • Forgetting that payments made outside India are ALWAYS 100% disallowed.
  • Thinking the disallowed amount is lost permanently — it is allowed in the later year of deduction/remittance.
  • Claiming income tax / surcharge / cess as a business deduction — disallowed u/s 40(a)(ii).
  • Overlooking that tax on non-monetary perquisites borne by employer is disallowed to employer but exempt to employee u/s 10(10CC).
Reference: Section 40(a)
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