TDS Transition Working Paper — Section 393 Mapping Guide
TDS Transition Working Paper — Section 393 Mapping (Income Tax Act 2025)
Deductor: {{client_name}} | TAN: {{client_tan}} | Tax year: 2026-27
1. Objective
From 1 April 2026, sums paid or credited are governed by the withholding provisions of the Income Tax Act, 2025: salary TDS moves from Sec 192 to Sec 392, every non-salary TDS provision (the old 193 / 194-series / 195) consolidates into Sec 393, and TCS moves from Sec 206C to Sec 394. This working paper is the firm's per-deductor control sheet for the first year on the new machinery — it records the section mapping the client's payments follow, the renumbered certificates and returns, and the quarterly filing status for tax year 2026-27.
2. How Section 393 Is Organised
Sec 393 replaces the scattered 194-series with three tables organised by payee: Sec 393(1) — payments to residents (interest, rent, contractor payments, commission, professional fees, dividends, purchase of goods and the other resident categories); Sec 393(2) — payments to non-residents, replacing the old Sec 195, applying whenever the sum is chargeable to tax in India; and Sec 393(3) — payments to any person. Each entry carries a serialized payment code used in challans and returns, so the software mapping in Section 4 below must be verified against the codes, not just the section numbers. The no-PAN higher rate (old Sec 206AA) is now Sec 397(2).
3. Section Mapping — Old Citations Used by This Deductor
| Old provision (1961 Act) | New provision (2025 Act) | Payments covered for this deductor | Applicable? (Y/N) |
|---|
| Sec 192 — salary | Sec 392 | Salaries | |
| Sec 193 / 194 / 194A–194T — non-salary payments to residents | Sec 393(1) table (with payment codes) | Interest, rent, contractors, commission, professional fees, dividends, purchase of goods, others | |
| Sec 195 — payments to non-residents | Sec 393(2) table | Royalty, FTS, imports of services, other sums chargeable to tax in India | |
| Sec 206C — TCS | Sec 394 | TCS on specified receipts | |
| Sec 206AA — no-PAN higher rate | Sec 397(2) | Deductees without PAN | |
4. Certificate and Return Renumbering
| Old form (Rules, 1962) | New form (Rules, 2026) | What it is | First due for tax year 2026-27 | Status |
|---|
| Form 16 | Form 130 | Salary TDS certificate | | |
| Form 16A | Form 131 | Non-salary TDS certificate (quarterly) | | |
| Form 24Q | Form 138 | Quarterly TDS return — salary | | |
| Form 26Q | Form 140 | Quarterly TDS return — residents, non-salary | | |
| Form 27Q | Form 144 | Quarterly TDS return — non-residents | | |
| Form 27EQ | Form 143 | TCS return | | |
| Forms 26QB / 26QC / 26QD / 26QE | Form 141 (separate schedules) | Challan-cum-statements for specified payments | | |
| Form 26AS | Form 168 | Annual information statement (deductee side) | | |
| Forms 15G / 15H | Form 121 (merged) | Self-declaration for no deduction | | |
- Working note: returns and certificates for Q4 of FY 2025-26 and any earlier-period corrections continue on the OLD forms under the 1961 Act — the new numbers apply to sums paid or credited on or after 1 April 2026.
- Working note: verify the TDS software's payment-code mapping (old section → Sec 393 code) against the utility before the first quarterly filing; do not assume the vendor default is complete.
5. Quarterly Filing Tracker — Tax Year 2026-27
| Quarter | Form 138 (salary) | Form 140 (residents) | Form 144 (non-residents) | Form 143 (TCS) | Certificates issued (130 / 131) |
|---|
| Q1 (Apr–Jun) | | | | | |
| Q2 (Jul–Sep) | | | | | |
| Q3 (Oct–Dec) | | | | | |
| Q4 (Jan–Mar) | | | | | |
6. Conclusion
Based on the mapping in Sections 3 and 4 and the tracker in Section 5, the deductor's TDS compliance for tax year 2026-27 has been transitioned to the Income Tax Act, 2025 structure, subject to the open items noted above.
For {{firm_name}}
Chartered Accountants
Firm Registration No.:
_______________________________
{{engagement_partner}} (Partner, Membership No. {{icai_membership_no}})
Date: 31 July 2026
