Harun Raaj & AssociatesHarun Raaj & Associates

India · jewellery cash counter

s.269ST, PMLA CTR and TCS checker

Enter every receipt from this customer before handing over the jewellery. Rows with the same invoice number are treated as one transaction.

Receipt entry

Same customer, today, including connected event invoices.

ModeAmountInvoice no.TimeRemove
STR judgment checklist
How this is computed

Daily cash: sum of every row whose mode is Cash. Current result: ₹0.

Single transaction: rows are grouped by invoice number. The “current invoice” is the last non-empty invoice number entered. Its all-mode total is ₹0 and its cash portion is ₹0. Limb (b) is also checked against every invoice group.

Event basket: when flagged, event cash equals all entered cash: ₹0.

s.269ST: a hit occurs at cash ≥ ₹2,00,000 for one person in one day, one transaction, or one event/occasion. The displayed s.271DA exposure uses 100% of the full prohibited receipt, not merely the excess over ₹2 lakh.

PMLA: a CTR card appears when current-transaction cash is ≥ ₹10,00,000 or entered connected month cash is ≥ ₹10,00,000.

STR cue: shown for refusal of ID with cash ≥ ₹50,000 or a user-identified avoidance pattern. It is deliberately not classified as an automatic statutory breach.

Operational screening aid only. Confirm current notifications, exemptions, reporting-entity status and TCS applicability with your CA or compliance officer.

Frequently asked questions

Does 269ST break if my customer pays in cash but takes home purchases across two days?

Yes, section 269ST(b) can still apply where the receipts relate to one transaction, even if cash is collected across two days. Section 269ST(a) is tested person-wise for the cash received on each day; do not rely only on the invoice date if the actual receipt date differs.

PMLA vs 269ST — what is the difference?

Section 269ST is an Income-tax Act restriction on receiving ₹2 lakh or more in cash under its day, transaction and event limbs, with potential penalty under section 271DA. PMLA creates a separate reporting and record-keeping obligation for covered reporting entities at ₹10 lakh for a single cash transaction or connected cash transactions aggregated during the month.

TCS 206C(1F) — do I collect on the whole invoice or the cash portion?

For the conservative cash-based check shown here, the calculation uses the cash portion, not non-cash consideration. However, the former jewellery-specific TCS provisions were restructured and omitted, while section 206C(1F) is principally framed for specified goods such as motor vehicles. Verify the current jewellery position with your CA before collecting TCS.

What if there is no PAN?

Where TCS applies, section 206CC may require collection at a higher rate when PAN is not furnished. Section 206AA separately governs higher-rate TDS where applicable. Obtain and validate PAN rather than treating a missing PAN as permission to accept cash.

What about marriage jewellery sold in five tranches over five days?

Section 269ST(c) can still aggregate the cash receipts because they relate to one event or occasion. Splitting the sale into invoices, tranches or days does not remove the event-limb restriction.

I already file GST and income tax returns — do I still need to register on FIU-IND for PMLA?

Yes, where you fall within the notified reporting-entity category. FIU-IND registration, record keeping, principal-officer arrangements and CTR/STR reporting are separate from GST and income-tax compliance.