TAN Registration: Who Needs One, Who Does Not, and How to Apply

Quick answer

Before you deduct a single rupee of TDS, you need a TAN — a Tax Deduction and Collection Account Number, a ten-character number that anyone deducting or collecting tax at source must obtain and quote on all TDS challans, statements and certificates. The obligation sits in section 397(1) of the Income-tax Act, 2025 for a deduction or collection on or after 1 April 2026.

Two things usually go missing. First, not everyone who deducts needs one: section 397(1)(c) exempts three of the commonest deduction obligations in India, and they are exactly the ones that land on people who have never run a payroll. Second, the application form changed. Under the Income-tax Rules, 2026 the section 397(1)(a) application is made in Form No. 134 by a Government entity and Form No. 135 by everyone else (Rule 216(1)). Form 49B is the familiar label under the superseded rules.

Who this page is for

Someone at a decision point: a founder about to run a first payroll, a buyer completing a flat purchase, a finance lead unsure whether the entity has a number at all.

This page is about the number itself. The catalogue of forms and dates is in our guide to TDS forms under the Income-tax Rules, 2026; the quarterly mechanics in our guide to filing TDS returns; the section a payment falls under in the TDS section crosswalk.

Which rulebook your application sits under

The Income-tax Act, 2025 came into force on 1 April 2026 — section 1(3) of that Act, not section 1(2), which is the extent clause. The Income-tax Rules, 2026 came into force the same day. Together they govern tax year 2026-27, which is FY 2026-27.

They do not govern assessment year 2026-27. That is the income of FY 2025-26, governed entirely by the Income-tax Act, 1961. The two obligations overlap in calendar 2026 and are independent of each other.

For a deduction the boundary turns on one unchanged test: tax is deducted at the time of credit of the sum to the payee's account or at the time of payment, whichever is earlier. If that earlier event fell on or before 31 March 2026, the 1961 Act and the Income-tax Rules, 1962 govern it; on or after 1 April 2026, the 2025 Act and the Income-tax Rules, 2026 do. A March 2026 provision credited to a vendor's account is an old-Act deduction even if the cheque cleared in May.

Who needs a TAN

• Employers deducting tax on salaries — under section 392, which sits outside section 393 entirely. There is no threshold table for salary: the obligation is to estimate the year's salary income and deduct at the average rate.
• Businesses paying rent, contractors, professionals, commission, interest or dividend above the section 393(1) thresholds.
• Anyone deducting on a payment to a non-resident under section 393(2) — a class wide enough that Table serial number 17 catches any other sum chargeable under the Act that is not salary.
• Anyone collecting tax at source under section 394. The "C" in TAN is not decorative: a scrap dealer or a tour operator collecting under section 394 needs the same number as a deductor.

If you will deduct or collect, you need the TAN first. Deducting without one, or failing to quote it, attracts a penalty.

The specified-person test that decides several rows

Several section 393(1) rows only bite where the payer is a "specified person", and the Income-tax Act, 2025 now states that test in figures rather than by cross-reference. Section 402(37): any person other than an individual or HUF, or an individual or HUF whose sales, gross receipts or turnover exceeded ₹1 crore in business or ₹50 lakh in profession in the immediately preceding tax year.

A company, LLP, firm, trust or society is always a specified person. A sole proprietor below those limits is not — which is no licence to ignore TDS. It moves them into narrower rows carrying larger thresholds and, as it happens, their own exemption from needing a TAN.

Who does not need a TAN

This is the half of the question most guides skip. Section 397(1)(c) exempts a person deducting under three section 393(1) rows from applying at all:

These are not small-print exceptions. They are the obligations that arrive at the door of someone who has never deducted anything: a flat buyer, a tenant, a household paying a contractor to renovate.

The clause as enacted also names a person referred to in section 393(4), Table serial number 12.C(a), a sub-item of the no-deduction table for virtual digital assets. We did not verify its terms, so we do not describe who falls inside it.

What replaces the TAN: Form No. 141, and then Form No. 132

An exempt deductor does not escape reporting. They report on a challan-cum-statement, against their PAN.

Under Rules 218(3) and 219(5), tax deducted under section 393(1), Table serial numbers 2(i), 3(i), 6(ii) and 8(vi) is paid within thirty days from the end of the month of deduction, with a challan-cum-statement in Form No. 141; the same thirty-day limit governs furnishing it. The deductee's certificate is Form No. 132, due within fifteen days from the Form No. 141 due date, under Rule 215(1), serial number 3.

One mismatch is worth catching. Serial number 8(vi), a transfer of a virtual digital asset, is on the Form No. 141 list under Rule 218(3) but is not in the section 397(1)(c) exemption as originally enacted. Reading the two side by side, a virtual digital asset deductor files a Form No. 141 and, until 1 October 2026, still needs a TAN to do it. That is our reading, not a published clarification.

Otherwise an exempt deductor has no quarterly statement and no annual certificate cycle. One payment, one Form No. 141, one Form No. 132.

What changes on 1 October 2026

Section 87 of the Finance Act, 2026 substitutes section 397(1)(c) with effect from 1 October 2026, widening the exemption to two more classes:

1. The virtual digital asset deductor under section 393(1), Table serial number 8(vi).
2. A resident individual or HUF deducting on consideration for the transfer of immovable property under section 393(2), Table serial number 17 — that is, buying property from a non-resident.

The second is the one to diarise. Until 30 September 2026 a resident individual buying a flat from an NRI must obtain a TAN, because that deduction is made under section 393(2) and not the section 393(1) row the exemption covered. From 1 October 2026 they do not. The date you complete changes what you have to register for.

The case we will not give you a form for

For that newly exempt purchase, no reporting form has been prescribed in the rules we were able to read. Rules 218(3) and 219(5) list only section 393(1) rows for the Form No. 141 route, and this deduction is made under section 393(2), Table serial number 17. The Act says the manner is as may be prescribed; we could not find the prescription.

So the TAN requirement goes on 1 October 2026, and what replaces the reporting is not something we can cite. Treat any page that confidently names a form for this case as guessing. Ask the Assessing Officer, or take advice, before you complete. Remitting the consideration abroad is a separate obligation under Rule 220 — Form No. 145, with an accountant's certificate in Form No. 146 above ₹5,00,000 — which our 15CA and 15CB filing service covers.

TAN vs PAN

• PAN identifies a taxpayer — the person whose own income is being assessed.
• TAN identifies you in a different capacity: as a person who deducts or collects tax out of someone else's income and holds it for the Government.

They are different numbers for different purposes, and you quote TAN, not PAN, on TDS documents. Two roles, two identifiers, two sets of consequences: a mistake on your PAN affects your own assessment; a mistake on your TAN affects the credit your deductees can claim.

The one place PAN does the work of a TAN is the exempt class above: a flat buyer files Form No. 141 against their PAN. A payee with no PAN is a different problem — under section 397(2)(b) the deduction is then at the higher of the rate in the provision, the rates in force, or 5% for purchases of goods and e-commerce payments and 20% in any other case. It is not, and never was, a flat 20% everywhere.

How to apply (Form 49B)

The application steps have not changed in substance. What you provide is:

1. The deductor's name, status and address — status meaning company, firm, individual, HUF, local authority, Government entity and so on, because it decides your form.
2. The details of the person responsible for deducting or collecting.
3. The application itself, filed through the authorised facility.
4. The department processes the application and allots the number.

We state no turnaround time: no statutory period fixes one. Apply ahead of the date you need it.

Form 49B is the widely used label for this application under the superseded rules and remains the reference point for anything filed under them. We carry it for orientation, the way the profession still says "26QB" or "24Q", rather than as quoted law — the Income-tax Rules, 1962 were not part of what we could capture, so nothing here quotes them.

Under the Income-tax Rules, 2026: Form No. 134 or Form No. 135

For an application under section 397(1)(a), Rule 216(1) splits the form by applicant:

That split is the only part of Rule 216 we assert. Pick by status, not by size or by what you are deducting on. If you would rather not run the application yourself, we file it.

After you get it

Holding a TAN starts three clocks. What follows is what the number obliges you to do; the TDS forms guide carries the full catalogue and the TDS return filing guide the quarterly mechanics.

Depositing the tax — Rule 218

Rule 218(4) adds a concession most deductors never use: in special cases the Assessing Officer may, with the prior approval of the Joint Commissioner, permit quarterly payment of tax deducted under section 392(1) or section 393(1), Table serial numbers 1(i), 1(ii), 5(ii) and 5(iii) — 7 July, 7 October, 7 January and 30 April. A permission, not an option you elect.

The statements and the certificates — Rules 219 and 215

Rule 219(1) identifies the quarterly statement by the sections it carries, not by the form it replaces; Rule 215(1) pairs each with a certificate for the deductee.

Rule 219(4) sets the statement dates: 31 July, 31 October and 31 January of the financial year for the quarters ending 30 June, 30 September and 31 December, and 31 May of the financial year immediately following the tax year for the quarter ending 31 March. So the first quarter of tax year 2026-27 fell due on 31 July 2026 and the March 2027 quarter falls due on 31 May 2027.

Certificates are generated and downloaded from the portal specified by the Director General of Income-tax (Systems) under Rule 215(1), not free-typed by the deductor. Separately, a payee seeking a lower rate or none at all applies under section 395(1), or section 395(3) for lower collection, in Form No. 128 under Rule 213; you deduct at the certificate rate while it is valid and keep it on file to defend that rate later.

Old labels, new numbers

This mapping is MyFinancialAdvisory's derivation from the section coverage set out in each rule. The Central Board of Direct Taxes has published no concordance between the old forms and the new ones, and any page presenting one as official is overstating what exists.

Read the right-hand column as the law and the left as orientation. The rules identify a form by the sections whose deductions it carries, never by the form it succeeds, so check the section coverage before assuming a straight swap.

Worked example 1: a new employer, before the first payroll

Assumptions: a private limited company incorporated in May 2026; its first salary payment is made on 30 June 2026 to two employees whose estimated income for the tax year makes tax deductible; it also credits ₹60,000 a month of office rent for a building to a resident landlord; employees and landlord have furnished valid PAN; nobody holds a certificate under section 395; the company is not a Government entity.

Does it need a TAN? Yes. It deducts under section 392 on salary and under section 393(1) on rent, and neither is in the section 397(1)(c) exemption. A company is a specified person under section 402(37) whatever its turnover, so the rent falls in the specified-person rent row at 10% for a building, with a threshold of ₹50,000 for a month or part of a month — which ₹60,000 crosses. That is ₹6,000 a month of rent TDS.

What it must do, in order:

1. Before 30 June 2026 — apply under section 397(1)(a) in Form No. 135 (Rule 216(1); it is not a Government entity). Do this well ahead: no statutory turnaround is fixed.
2. By 7 July 2026 — deposit the June deductions (Rule 218(2), seven days from the end of the month of deduction).
3. By 31 July 2026 — file the quarter-ended-30-June statements (Rule 219(4)). Two statements, not one: Form No. 138 for the salary, Form No. 140 for the rent.
4. By 15 August 2026 — issue the landlord Form No. 131, within fifteen days of the Rule 219 due date.
5. By 15 June 2027 — issue the employees Form No. 130 for tax year 2026-27.

If it skips step 1 and deducts anyway: ₹10,000 under section 468(1), plus interest under section 398(3)(a), plus the ₹200-a-day fee under section 427 on any late statement, plus a 30% disallowance of the rent under section 35(b)(i) if the tax is not paid by the return due date. The registration is the cheapest item on that list.

Worked example 2: an individual buying a flat, who needs no TAN at all

Assumptions: a salaried resident individual with no business or profession, buying a completed flat from a resident seller; consideration ₹95,00,000; stamp duty value ₹98,00,000; one buyer, one seller; the whole consideration paid on 18 September 2026; the seller has furnished a valid PAN; no certificate under section 395.

How much? Section 393(1), Table serial number 3(i): 1% of the consideration or the stamp duty value, whichever is higher. The stamp duty value is higher, so the base is ₹98,00,000 and the deduction is ₹98,000. The ₹50 lakh threshold aggregates across all transferees and transferors, so a joint purchase does not split anyone below it.

Does the buyer need a TAN? No. Section 397(1)(c) exempts this row, and the challan-cum-statement route works off PAN. Applying for a TAN here is a common and needless step.

The two dates that replace the TAN calendar:

• The deduction is made in September 2026. That month ends on 30 September, and Rules 218(3) and 219(5) give thirty days from the end of the month — so the tax is paid and Form No. 141 furnished by 30 October 2026.
• The seller's certificate in Form No. 132 follows within fifteen days of that due date — 14 November 2026 — under Rule 215(1), serial number 3.

The arithmetic is shown so you can check it against the rule. There is no quarterly statement and no annual certificate: one deduction, one Form No. 141, one Form No. 132.

Change one fact — the seller is a non-resident — and the answer changes twice. The deduction then falls under section 393(2), not section 393(1). Complete before 30 September 2026 and the buyer needs a TAN. Complete on or after 1 October 2026 and, under section 397(1)(c) as substituted by section 87 of the Finance Act, 2026, they do not — but as set out above, no reporting form for that case is prescribed in the rules we read, and we will not name one.

What it costs to get this wrong

The ₹10,000 is rarely the expensive part. The disallowance usually is.

Common mistakes

• Deducting before the TAN exists. The obligation to deduct does not wait for your registration, and the penalty for not having the number is separate from the penalty for not deducting.
• Quoting PAN instead of TAN. They identify you in different capacities, and a statement filed against the wrong identifier does not credit your deductees.
• Mismatched deductor details on the application. Name, status and responsible-person details follow you into every challan and statement; a mismatch surfaces later, at correction cost.
• Forgetting a TAN is needed even for a single qualifying payment. One payment above a threshold creates it.
• Applying for a TAN you do not need. A flat buyer, a tenant under serial number 2(i) and a small individual or HUF under serial number 6(ii) are expressly exempt; registering anyway creates a statement obligation that did not exist.
• Filing the wrong application form. Rule 216(1) splits on whether the applicant is a Government entity — Form No. 134 — or not, which is Form No. 135. It does not split on what you deduct on.
• Assuming the specified-person test is about being "a business". It is a figure: ₹1 crore in business or ₹50 lakh in profession in the immediately preceding tax year, under section 402(37).
• Reading the rent threshold as annual. For serial number 2(i) it is ₹50,000 for a month or part of a month, deducted once against the last month.
• Assuming a missing PAN means 20%. Section 397(2)(b) sets a 5% floor for purchases of goods and e-commerce payments.

What this guide does not claim

• A reporting form for a resident individual or HUF buying immovable property from a non-resident on or after 1 October 2026. The rules we read prescribe none for a section 393(2) deduction.
• A processing or allotment time for a TAN application. No statutory period fixes one.
• Anything quoted from the Income-tax Rules, 1962 or the Income-tax Act, 1961. Neither was part of what we could capture, so old form numbers — 49B, 24Q, 26Q, 27Q, 27EQ, 16, 16A, 26QB, 26QC, 26QD, 26QE — appear only as widely used labels for orientation, with no before-and-after legal comparison drawn from them. The old-to-new mapping is our derivation; CBDT has published no concordance.
• The internal structure of Form No. 141, or the terms of section 393(4), Table serial number 12.C(a) which the TAN exemption also names. Neither was verified.
• A rate for a payment to a non-resident. Those turn on the rates in force read with treaty relief under section 159 — our guide to TDS on payments to non-residents explains why a general page cannot state them safely.

Get the number in place first — or establish that you do not need it — and your TDS compliance starts on the right footing.

Sources and currency

Applies to: Deductions and collections where the earlier of credit or payment falls on or after 1 April 2026 — tax year 2026-27 onward, under the Income-tax Act, 2025 and the Income-tax Rules, 2026. An earlier event stays under the Income-tax Act, 1961 and the Income-tax Rules, 1962. Assessment year 2026-27 is the income of FY 2025-26 and is entirely old-Act territory.

Every form number, rule number, section number, figure and date on this page was read from the gazette text of the Income-tax Act, 2025, the Finance Act, 2026 and the Income-tax Rules, 2026 — G.S.R. 198(E) dated 20 March 2026, made by the Central Board of Direct Taxes under section 533 of the Income-tax Act, 2025 — on 20 August 2026. Three things on this page are our reading rather than published law, and each is marked where it appears. First, the old-form-to-new-form lookup is MyFinancialAdvisory's derivation from the section coverage set out in each rule; the Central Board of Direct Taxes has published no concordance. Second, Form 49B is carried here as the widely used label for the application under the superseded rules, for reader orientation, not as quoted law — the Income-tax Rules, 1962 were not part of what we could capture. Third, one case has no answer we are willing to give, and it is set out in full below. Rules change at each notification and each Finance Act; confirm the current position before you rely on a date or a form number for a filing.

• Income-tax Rules, 2026 — G.S.R. 198(E) dated 20 March 2026, Gazette of India Extraordinary, Part II section 3 sub-section (i), made by CBDT under section 533 of the Income-tax Act, 2025. Rule 213 (Form No. 128), Rule 215 (Forms 130 to 133), Rule 216 (Forms 134 and 135), Rule 218 (deposit), Rule 219 (Forms 138 to 144) and Rule 220 (Forms 145 and 146)
• Income-tax Act, 2025 (No. 30 of 2025) — Gazette of India Extraordinary, 21 August 2025. Section 1(3) commencement, section 392 (salary), section 393 (other payments), section 394 (collection), section 395 (certificates), section 397 (TAN, no-PAN rate, payment and statements), section 402(37) (specified person) and section 468 (TAN penalties)
• Finance Act, 2026 (No. 4 of 2026) — Gazette of India Extraordinary, 30 March 2026. Section 87 substitutes section 397(1)(c) with effect from 1 October 2026
• Income Tax Department, e-filing portal — TDS Compliance