Income Tax

CBDT notifies conditional TDS and TCS treatment for payments received by IRRI

Notification 138/2026 excludes covered receipts of the International Rice Research Institute from Chapter XIX, subject to the cited privileges and immunities conditions.

Published by Mohit R Gupta & AssociatesChartered Accountants · Delhi

REFERENCECBDT Notification No. 138/2026 · S.O. 5855(E) · F. No. 275/44/2026-IT(B)
SOURCE CHECKED05-11-26
EFFECT / APPLICABILITYEffective on Gazette publication on 28 October 2026. Applies to covered payments received by IRRI.

The Central Government issued Notification 138/2026 under section 400(1) of the Income-tax Act, 2025. It provides that Chapter XIX, which deals with deduction and collection of tax at source, does not apply to payments received by the International Rice Research Institute (IRRI), subject to the specified conditions. The notification commenced when published in the Official Gazette on 28 October 2026.

The conditions are those in the United Nations (Privileges and Immunities) Act, 1947, read with the Ministry of External Affairs’ Notification S.O. 3230(E) of 3 October 2017. The new notification identifies IRRI as the recipient. Payments made to other entities or transactions outside the specified conditions need their own review under the usual provisions.

Finance teams handling an IRRI payment should match the legal payee on the contract and invoice, retain the Gazette notification with the payment working, and document why the cited conditions apply. The notification addresses income-tax deduction and collection at source on covered receipts. Review any GST obligations separately.

WHAT TO DO NEXT

Practical action

Before applying the treatment, confirm IRRI is the payee and review the applicable conditions in the 1947 Act and MEA Notification S.O. 3230(E).

Read the official publication ↗egazette.gov.in · CBDT Notification No. 138/2026 · S.O. 5855(E) · F. No. 275/44/2026-IT(B)

This summary is general information. Read the original publication and check subsequent amendments before acting. For advice on your specific facts, consult our office.

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