From 1961 to 2025: Navigating the New Era of Indian TDS Compliance

The Income-tax Act, 2025: Converts section-based TDS to Table-based system (Clause 393) Rationalises thresholds Retains majority rates Clarifies TDS vs TCS hierarchy Introduces structural simplification

From 1961 to 2025: Navigating the New Era of Indian TDS Compliance

Introduction: The Great Tax Migration

For over six decades, the Income-tax Act, 1961 served as the primary bedrock of Indian fiscal regulation. However, decades of incremental amendments, combined with the explosive growth of a complex digital economy, eventually necessitated a significant structural overhaul. This transition, brought about by the Finance Act, 2025, represents a modernization of the existing framework—a migration from a legacy system toward a streamlined, data-driven compliance environment.

For tax professionals and financial controllers, the most immediate challenge of this "Great Migration" is the retirement of familiar compliance landmarks. The long-standing numbering system for Tax Deducted at Source (TDS) and Tax Collected at Source (TCS) forms is being overhauled, replaced by a logical 138–144 series. As a strategist, it is essential to look beyond the surface level of these renumberings to understand the consolidated architecture that now governs reporting.

TDS Comparison

Old Income-tax Act, 1961 vs Income-tax Act, 2025

(Clause 393 – Table Based Framework)

As we all know, the Income-tax Act, 2025 removes the earlier section-wise TDS structure (like 194C, 194J, 194H etc.) and consolidates all deduction provisions into:

Clause 393 – TDS (Table Driven Structure)
Clause 394 – TCS (Table Driven Structure)

Each nature of payment is now governed through a Table Serial Number (Sl. No.), instead of separate sections.

Below is the perfected comparison.

 

1. Salary

Particular

Old Act (Sec 192)

New Act (Clause 393 – Salary Entry)

Threshold

Basic exemption slab

Basic exemption slab

Rate

As per slab

As per slab

Timing

At time of payment

Same

✔ No structural change except codification shift.

 

2. Interest on Securities

Particular

Old Act (Sec 193)

New Act (Clause 393 – Table Sl. No. 5)

Threshold

₹5,000 (listed securities – certain cases)

Same

Rate

10%

Rates in Force

✔ “Rates in Force” concept introduced in place of fixed % in certain cases.

 

3. Dividend

Particular

Old Act (Sec 194)

New Act (Clause 393 – Table Sl. No. 1)

Threshold

₹5,000

₹10,000

Rate

10%

10%

✔ Threshold enhanced.

 

4. Interest (Other than Securities)

Particular

Old Act (Sec 194A)

New Act (Clause 393 – Table)

Threshold (General)

₹5,000

₹5,000

Bank / PO

₹40,000

₹40,000

Senior Citizens

₹50,000

₹50,000

Rate

10%

10%

✔ Threshold retained.

 

5. Contractor Payments

Particular

Old Act (Sec 194C)

New Act (Clause 393 – Table)

Single Contract

₹30,000

₹30,000

Aggregate

₹1,00,000

₹1,00,000

Rate – Individual/HUF

1%

1%

Rate – Others

2%

2%

✔ No change except structural.

 

6. Commission / Brokerage

Particular

Old Act (Sec 194H)

New Act (Clause 393 – Table)

Threshold

₹15,000

₹20,000

Rate

5%

2%

✔ Major rationalisation.

 

7. Professional / Technical Services

Particular

Old Act (Sec 194J)

New Act (Clause 393 – Table)

Threshold

₹30,000

₹50,000

Rate – Technical

2%

2%

Rate – Professional

10%

10%

Director Fees

10%

10%

✔ Threshold increased.

 

8. Rent

Particular

Old Act (Sec 194I)

New Act (Clause 393 – Table)

Threshold

₹2,40,000 (annual)

₹50,000 per month

Plant & Machinery

2%

2%

Land/Building

10%

10%

✔ Monthly alignment introduced.

 

9. Purchase of Immovable Property

Particular

Old Act (Sec 194IA)

New Act (Clause 393 – Table)

Threshold

₹50 Lakh

₹50 Lakh

Rate

1%

1%

✔ No change.

 

10. Purchase of Goods

Particular

Old Act (Sec 194Q)

New Act (Clause 393 – Table Sl. No. 8(ii))

Threshold

₹50 Lakh

₹50 Lakh

Rate

0.1%

0.1%

✔ TDS overrides TCS (Clause 394).

 

11. E-Commerce Operator

Particular

Old Act (Sec 194O)

New Act (Clause 393 – Table Sl. No. 8(v))

Threshold

₹5 Lakh (Individual/HUF)

₹5 Lakh

Rate

0.1%

0.1%

✔ No change.

 

12. Virtual Digital Assets

Particular

Old Act (Sec 194S)

New Act (Clause 393 – Table)

Threshold

₹10,000 / ₹50,000

Same

Rate

1%

1%

✔ No change.

 

13. Benefits / Perquisites

Particular

Old Act (Sec 194R)

New Act (Clause 393 – Table)

Threshold

₹20,000

₹20,000

Rate

10%

10%

✔ No change.

 

14. Cash Withdrawal

Particular

Old Act (Sec 194N)

New Act (Clause 393 – Table)

Threshold

₹1 Crore

₹1 Crore

Rate

2%

 

Non-filers

2% / 5%

 

✔ Retained.

 

15. Lottery / Online Gaming

Particular

Old Act (Sec 194B / 194BA)

New Act (Clause 393 – Table)

Threshold

₹10,000

₹10,000

Rate

30%

30%

✔ No change.

 

16. Insurance Commission

Particular

Old Act (Sec 194D)

New Act (Clause 393 – Table)

Threshold

₹15,000

₹20,000

Rate

5%

5%

✔ Threshold aligned.

 

17. Non-Resident Payments

Particular

Old Act (Sec 195)

New Act (Clause 393 – Table)

Threshold

No minimum

No minimum

Rate

Rates in Force

Rates in Force

✔ No structural change.

 

18. PAN Not Furnished

Old Act (Sec 206AA)

New Act (Clause 393 + Compliance Clause)

20% or applicable rate

20% or applicable rate


 Compliance Mechanics (Same in Substance)