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Liquidated Damages and "Agreeing to Tolerate an Act"

Circular 178/10/2022-GST rewrote the analysis: a payment flowing from a breach is not consideration for tolerating it. Where that leaves damages, penalties and...

Vikas Sharma Tax & Compliance Expert
6 min read 7 views Updated Sep 8, 2026 Expert Reviewed Medium Complexity
Liquidated Damages and "Agreeing to Tolerate an Act"
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Last updated: September 2026Applies to: FY 2026-27Verified against: Government sources
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Circular 178/10/2022-GST rewrote the analysis: a payment flowing from a breach is not consideration for tolerating it. Where that leaves damages, penalties and...

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Schedule II paragraph 5(e) treats as a supply of services: "agreeing to the obligation to refrain from an act, or to tolerate an act or a situation, or to do an act."

For five years that entry was read as a catch-all. Departments applied it to liquidated damages, contractual penalties, forfeited earnest money, notice pay recovery, cheque bounce charges, cancellation fees — on the reasoning that the recipient of the money had "tolerated" the payer's default.

Circular No. 178/10/2022-GST dated 03.08.2022 rejected that reading, and the ICAI commentary in Volume I treats it as the governing analysis.

The test the circular applies

Three questions, in order:

1. Is there an express or implied agreement to do, refrain from, or tolerate something? Not a contract that happens to contain a damages clause — an agreement whose subject matter is the forbearance.

2. Is there a direct link between that agreement and the payment? The payment must be consideration for the forbearance, not merely occasioned by an event.

3. Did the parties intend the payment as the price of a permitted alternative, or as a deterrent against breach? A deterrent is not a price.

The circular's central point: liquidated damages under s.74 of the Indian Contract Act, 1872 are a remedy for breach. The contract did not offer the counterparty a choice to perform or pay; it required performance. Damages flow from the failure. Nobody agreed to tolerate anything.

Where each common payment lands

PaymentPosition
Liquidated damages for delay or non-performanceNot taxable — compensation for breach
Penalty for breach of contractNot taxable, same reasoning
Forfeiture of earnest money or security deposit on defaultNot taxable — flows from breach, and serves as a deterrent
Cheque dishonour chargesNot taxable — the payee never agreed to tolerate dishonour
Late payment surcharge or interestTaxable, but not under 5(e) — s.15(2)(d) includes interest, late fee or penalty for delayed payment in the value of the underlying supply
Cancellation charges on a bookingTaxable — facilitation of the booking is itself a service; the cancellation charge is consideration for it
Notice pay recovery from an employeeNot taxable — the employment contract's alternative, and Schedule III excludes employment
Compensation for pre-mature termination of a lease, agreed in the contractFact-specific — where the contract prices termination as an option, it can be taxable
Fine or penalty imposed by a statute or courtNot taxable — no agreement at all

The two rows that most often surprise people are late payment interest and cancellation charges.

Late payment interest is taxable, but as part of the value of the original supply under s.15(2)(d), at the original supply's rate — not as a separate 18% service. That distinction matters where the underlying supply is at 5% or exempt.

Cancellation charges are taxable because the supplier provided a real service — reserving and holding the booking — and the charge is consideration for that, not damages. This is why a hotel or airline cancellation fee bears GST at the rate of the underlying service.

The distinction that decides the hard cases

Ask whether the contract gave the counterparty a genuine option.

No option — pure breach. "Deliver by 31 March. Damages of ₹1 lakh per week of delay." The contractor was never permitted to deliver late. Damages are compensation. Not taxable.

Genuine option — priced alternative. "Take a minimum of 1,000 units, or pay ₹50 per unit short-lifted." Here the buyer may lawfully choose either. The short-lift charge is the price of the alternative, and the supplier agreed in advance to tolerate under-lifting. Taxable.

The drafting will not always be clear, and a "penalty" label does not settle it. What settles it is whether performance was required or elective.

Practical consequences

Do not charge GST reflexively on damages. Charging tax that was never leviable engages s.32 and s.76 — the amount is payable to the Government whether or not the supply was taxable. Collecting tax you should not have →

Do not omit it reflexively either. A "penalty" that is really a priced option is a supply, and non-payment is a demand with interest.

Get the credit note right on damages deducted from a running bill. Where a customer deducts liquidated damages from the contractor's invoice, the deduction is not a reduction in the value of the supply — the contractor supplied the full scope and was compensated less. A credit note under s.34 is usually inappropriate; the tax stays on the gross value.

Document the characterisation in the contract, and again when the amount is levied.

Key takeaways

  • Circular No. 178/10/2022-GST governs: paragraph 5(e) requires an independent agreement to tolerate, with a direct link to the payment.
  • Liquidated damages and breach penalties are generally not taxable.
  • Forfeited earnest money and cheque bounce charges are not taxable.
  • Late payment interest is taxable — under s.15(2)(d), at the underlying supply's rate.
  • Cancellation charges are taxable as consideration for the booking service.
  • The dividing line is whether the contract offered a genuine priced alternative or required performance.

Read next

Disclaimer: Positions stated as on 5 September 2026, based on ICAI Background Material on GST, Volume I (2026 edition) and Circular No. 178/10/2022-GST.

Key Facts About Liquidated Damages and

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

Is GST payable on liquidated damages?

Generally no. Circular No. 178/10/2022-GST holds that damages flowing from a breach are compensation, not consideration for agreeing to tolerate an act.

Are forfeited security deposits taxable?

No, where the forfeiture flows from the counterparty's default. It is a deterrent against breach, not the price of a permitted alternative.

Over 90% of compliance penalties in India arise from missed due dates — timely handling can save businesses thousands of rupees each year.

— TaxClue Compliance Desk

Liquidated Damages and: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

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Frequently Asked Questions
Is GST payable on liquidated damages?
Generally no. Circular No. 178/10/2022-GST holds that damages flowing from a breach are compensation, not consideration for agreeing to tolerate an act.
Are forfeited security deposits taxable?
No, where the forfeiture flows from the counterparty's default. It is a deterrent against breach, not the price of a permitted alternative.
Is GST payable on late payment interest?
Yes, but as part of the value of the original supply under section 15(2)(d), at that supply's rate — not as a separate service at 18%.
Are cancellation charges taxable?
Yes. The supplier provided a booking service and the cancellation charge is consideration for it, taxable at the rate of the underlying supply.
Is notice pay recovery from an employee taxable?
No. It arises out of the employment contract, and Schedule III excludes services by an employee to the employer in the course of employment.
How do I tell a damages payment from a priced option?
Ask whether the contract permitted the counterparty to choose. If performance was required, the payment is damages. If the contract priced an alternative the counterparty could lawfully take, it is consideration.
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Vikas Sharma VERIFIED EXPERT
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Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

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