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Section 187 · Mode of payment

Section 187 of the Income-tax Act, 2025 — Mandatory Acceptance of Payment Through Prescribed Electronic Modes (UPI/RuPay)

By CA Rajat Agrawal Updated 04 Jul 2026 Chapter XII
📜 What the law says — Section 187, Income-tax Act 2025
187. Every person shall provide facility for accepting payment, through electronic modes as may be prescribed, in addition to other electronic modes, if any, being provided by him, where— (a) such person is carrying on business or profession; and (b) total sales, turnover or gross receipts in such business or profession exceeds fifty crore rupees during the immediately preceding tax year. Mode of repayment of certain loans or deposits or specified advances.

In plain language

What Section 187 actually says

Section 187 has nothing to do with transfer pricing. It is the successor to Section 269SU of the old Income-tax Act, 1961, and it deals with mandatory acceptance of digital payments. In plain words: if you run a large business or profession, you must give your customers a way to pay you electronically through the specific modes the Government prescribes — such as BHIM-UPI, UPI QR code and RuPay debit cards — and you cannot charge them for using those modes.

The exact wording requires every person carrying on business or profession, whose total sales, turnover or gross receipts exceed ₹50 crore during the immediately preceding tax year, to provide a facility for accepting payment through prescribed electronic modes, in addition to any other electronic modes already being offered.

Who this applies to

  • Large taxpayers only. The ₹50 crore turnover/gross-receipts threshold is tested on the immediately preceding tax year (previous year). If you crossed ₹50 crore last year, you must offer the facility this year.
  • Business AND profession. A notable widening from the old law: Section 269SU (1961) applied only to a person "carrying on business." Section 187 (2025) reads "business or profession," so large professional firms (for example, big consultancy, legal or medical set-ups) also fall within its net.
  • Not for small taxpayers. If your turnover is at or below ₹50 crore, this section does not compel you to install any particular payment mode.

What "prescribed electronic modes" means

The section itself does not list the modes — it leaves them to be prescribed by the CBDT through rules/notifications (carried over from Rule 119AA and Notification 105/2019 under the 1961 regime). The historically prescribed modes are:

  • Debit card powered by RuPay
  • Unified Payments Interface (UPI) — BHIM-UPI
  • UPI Quick Response Code — BHIM-UPI QR Code

You may offer other modes (credit cards, Visa/Mastercard debit, wallets, NEFT) as well, but you must at minimum provide the prescribed low-cost modes.

No charges — the "zero MDR" rule

A key protection sits outside the Income-tax Act, in Section 10A of the Payment and Settlement Systems Act, 2007. It says no bank or system provider may impose any charge — directly or indirectly, including Merchant Discount Rate (MDR) — on a payer or the merchant for transactions made through the prescribed modes. So a customer paying you via BHIM-UPI or RuPay debit card pays nothing extra, and you as the merchant bear no MDR on those specific rails.

Penalty for non-compliance — Section 452

  • Failure to provide the facility attracts a penalty under Section 452 of the 2025 Act (the successor to Section 271DB of the 1961 Act).
  • The penalty is ₹5,000 for every day during which the failure continues.
  • The penalty is not automatic: it will not be levied if you prove there were good and sufficient reasons for the failure. It is imposed by the Joint Commissioner (a senior officer), not the assessing officer alone.

How it interacts with related sections

  • Section 452 is the penalty engine that gives Section 187 its teeth.
  • It complements the cash-discouragement provisions (limits on cash receipts and cash expenditure) — the whole scheme nudges the economy toward a digital, traceable payment trail.
  • It sits alongside TDS/reporting requirements: digital acceptance creates a clean audit trail that dovetails with the Act's information-reporting framework.

Practical implications

  • Effective 1 April 2026 under the new Act. Large firms should confirm a live UPI/RuPay acceptance channel (a UPI QR at the counter or a payment gateway online is usually enough).
  • Compliance is cheap: displaying a BHIM-UPI QR code that routes to your business account generally satisfies the requirement, and there is no MDR cost.
  • Keep evidence (screenshots, merchant onboarding records) showing the facility was live, in case a "good and sufficient reason" defence is ever needed.
💡 Example

Worked example 1 — a manufacturer. Shivam Industries Pvt. Ltd. had turnover of ₹62 crore in tax year 2025-26. Because it crossed ₹50 crore in the immediately preceding year, from 1 April 2026 it must offer at least one prescribed mode (say, a BHIM-UPI QR code at its billing counter and on its e-invoice). Suppose it ignores this and does not enable any prescribed mode for 40 days before the department notices. Penalty under Section 452 = ₹5,000 × 40 days = ₹2,00,000 — unless Shivam Industries can show a good and sufficient reason.

Worked example 2 — a professional firm (the widened net). Mehta & Associates, a large CA/consulting firm, earned ₹51 crore in gross professional receipts last year. Under the old Section 269SU (which covered only "business"), a pure profession arguably fell outside. Under the new Section 187, the words "business or profession" bring the firm squarely within the mandate, so it too must enable UPI/RuPay acceptance for client fees.

A relatable story. Priya runs a fast-growing chain of home-decor stores that just touched ₹55 crore in sales. Her accountant flags Section 187. Priya worried it would cost her card-machine fees — but learns that the prescribed modes (BHIM-UPI, UPI QR, RuPay debit) carry zero MDR because of Section 10A of the Payment and Settlement Systems Act. She sticks a UPI QR code at every till, links it to the company account, and is fully compliant at effectively no cost — while her customers enjoy tap-and-pay convenience.

FeatureSection 187, Income-tax Act 2025Section 269SU, Income-tax Act 1961 (old)
SubjectAcceptance of payment through prescribed electronic modesSame
Turnover thresholdExceeds ₹50 crore in immediately preceding tax yearExceeds ₹50 crore in immediately preceding previous year
Who is coveredPerson carrying on business or professionPerson carrying on business only
Prescribed modesRuPay debit card, BHIM-UPI, UPI QR code (as prescribed by CBDT)RuPay debit card, BHIM-UPI, UPI QR code (Rule 119AA)
Charge on payer/merchantNil — no MDR (Sec 10A, Payment & Settlement Systems Act 2007)Nil — no MDR (Sec 10A)
Penalty sectionSection 452Section 271DB
Penalty amount₹5,000 per day of failure (subject to reasonable-cause defence)₹5,000 per day of failure
Effective from1 April 20261 November 2019 / 1 January 2020

Related sections

Section 452 — Penalty for failure to comply with Section 187 (₹5,000/day) Section 269SU (1961 Act) — Old equivalent electronic-modes provision Section 271DB (1961 Act) — Old penalty for electronic-modes failure Rule 119AA — Prescribed electronic modes (RuPay, BHIM-UPI, UPI QR) Section 10A, Payment & Settlement Systems Act 2007 — No MDR/charges Section 44AB (concept) — Tax audit turnover thresholds

Frequently asked questions

Does Section 187 deal with transfer pricing?
No. Despite the label, Section 187 has nothing to do with transfer pricing. It mandates that large businesses and professionals accept payments through prescribed electronic modes such as BHIM-UPI and RuPay. Transfer-pricing rules sit in Chapter X (broadly Sections 161–173) of the 2025 Act.
What is the turnover limit that triggers Section 187?
The section applies if your total sales, turnover or gross receipts exceeded ₹50 crore during the immediately preceding tax year. If you are at or below ₹50 crore, the mandate does not apply to you.
Which electronic payment modes must I offer?
The Government prescribes the modes through CBDT rules/notifications. Historically these are RuPay debit card, BHIM-UPI and the UPI QR code. Offering at least these low-cost modes, in addition to anything else you already accept, satisfies the section.
Will I or my customers have to pay MDR on these payments?
No. Section 10A of the Payment and Settlement Systems Act, 2007 bars any bank or payment provider from charging MDR or any other fee — directly or indirectly — on payments made through the prescribed modes.
What is the penalty if I don't provide the facility?
Under Section 452 of the 2025 Act, the penalty is ₹5,000 for every day the failure continues. It is not levied if you can prove good and sufficient reasons for the failure.
Does Section 187 now cover professionals as well?
Yes. Unlike the old Section 269SU, which covered only 'business', Section 187 uses 'business or profession'. So large professional firms crossing ₹50 crore in gross receipts must also provide the facility.
From when is Section 187 effective?
It takes effect from 1 April 2026, along with the rest of the Income-tax Act, 2025 (as amended by the Finance Act, 2026).
C
CA Rajat Agrawal
Chartered Accountant, EaseValue · Reviewed 04 Jul 2026
This explainer is prepared and reviewed by EaseValue's tax team, based on the text of the Income-tax Act, 2025 (as amended by the Finance Act, 2026).
Disclaimer: This page explains the law in general terms for education and is not professional advice. The Income-tax Act, 2025 takes effect from 1 April 2026; provisions, thresholds and interpretations may change. Please confirm your specific position with our team before acting.

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