A branded apparel principal selling across Myntra, Ajio, and Flipkart Fashion faces three settlement files with three different commission grids (15-20% Myntra, 12-18% Ajio, 12-16% Flipkart Fashion), three payout cadences (T+15, T+7 to T+10, T+7), three return-handling models (dedicated bucket, integrated netting, separate adjustment schedule), and one Section 52 TCS aggregation at 0.5% into GSTR-8. The brand's own books must reflect a Section 9(1) normal supply (not 9(5) deemed supply — apparel is not notified), issue a Section 34 credit note for every return before the 30 November following FY cut-off, deduct 5% TDS under Section 194H on platform commission (payment code 1015), and claim 194-O credit at 1% deducted by the platform (payment code 1058). Manual per-platform reconciliation loses commission-invoice matches, mis-applies TCS to the wrong month, and mis-classes late returns — resulting in output GST over-payment, ITC leakage, and Section 73/74 notice exposure.
Ingest each platform's settlement file at native cadence (Myntra T+15, Ajio T+7 to T+10, Flipkart Fashion T+7) and decompose every row into six components — gross taxable, platform commission (Section 194H TDS at 5%), logistics or shipping charge, returns adjustment, Section 194-O TDS (1%) at source, and Section 52 TCS (0.5%) at source. Match every gross taxable entry to the brand's own sales register by order ID; match every commission line to the platform's tax invoice and the brand's TDS working; match every returns adjustment to a Section 34 credit note issued by the brand within the 30 November cut-off. Aggregate all three platforms' Section 52 TCS into a single quarterly ledger and reconcile against GSTR-2A after the platform files GSTR-8. Trace net-cash-in from each platform to the specific bank credit line in the brand's statement.
Platform master with settlement cadence (T+15 Myntra, T+7 to T+10 Ajio, T+7 Flipkart Fashion), commission grid ranges by SKU category, returns-handling model (bucket, integrated, or separate), and Section 194-O deducting-agent PAN; SKU-to-category master mapping brand SKUs to platform commission tiers; Section 52 TCS rate (0.5% per Notification 15/2024-CT); Section 34 credit-note deadline enforcement (30 November of following FY); Section 194H TDS payment code 1015 (5%) for commission bill deductions; Section 194-O TDS payment code 1058 (1%) reconciliation for platform-side deductions; GSTR-8 reconciliation window (platform files by 10th of following month; GSTR-2A visibility follows); bank statement narration patterns for identifying Myntra, Ajio, and Flipkart Fashion settlement credits.
A per-quarter three-platform reconciliation pack: platform-wise gross taxable, commission (with 194H TDS reconciled to Form 26AS at platform PAN), logistics, returns (with Section 34 credit-note tally against the 30 November cut-off), 194-O credit at the brand's PAN, Section 52 TCS aggregate against GSTR-2A, and net cash-in traced to the brand's bank statement. Per-order match rate across settlement file and internal sales register. GSTR-8 to GSTR-2A synchronisation health check. Alert list of returns booked by any platform after 30 November of the following FY that cannot recover output GST. Commission-invoice ITC claim reconciled to the platform's GSTR-1 filing at the platform's GSTIN.
A branded apparel controller closing Q3 FY 2026-27 books for a house of brands spanning premium and value tiers has three settlement files open on her desk — one from Myntra, one from Ajio, one from Flipkart Fashion — each in a different schema, each with a different payout cadence, each with its own return-handling logic. Aggregate quarterly online GMV across the three platforms sits at approximately ₹69 crore across roughly 1.2 million orders; net cash-in after commissions, logistics, returns, and taxes-at-source will settle around ₹55.16 crore; Section 52 TCS aggregate deducted at 0.5% across all three platforms sits at approximately ₹34.5 lakh. Every single line has to reconcile back to the sales register, to the platform commission invoice, to Section 194H TDS working, to a Section 34 credit note for every return, to the GSTR-8 filing at each platform’s GSTIN, and finally to the bank statement narration for each settlement credit. This is Myntra Ajio Flipkart Fashion apparel settlement reconciliation at production scale, and the discipline that closes the quarter cleanly is what separates a well-controlled apparel principal from a Section 73/74 GST notice at year-end audit.
Quick reference
| Aspect | Detail |
|---|---|
| Governing GST provision | Section 9(1) CGST (normal supply by brand) + Section 52 (TCS by ECO) |
| Section 9(5) applicability | Not applicable — apparel not in notified deemed-supplier categories |
| Section 52 TCS rate | 0.5% (0.25% CGST + 0.25% SGST intra-state; 0.5% IGST inter-state) |
| TCS rate notification | Notification 15/2024-Central Tax dated 10 July 2024 (reduced from 1%) |
| Platform GSTR-8 filing | Monthly by 10th of the following month |
| Brand TCS credit visibility | GSTR-2A after platform files GSTR-8 |
| Myntra settlement cadence | T+15 working days from dispatch/delivery |
| Ajio settlement cadence | T+7 to T+10 |
| Flipkart Fashion settlement cadence | T+7 |
| Myntra commission range | Approximately 15-20% by category |
| Ajio commission range | Approximately 12-18% by category |
| Flipkart Fashion commission range | Approximately 12-16% by category |
| Platform commission TDS (brand deducts) | Section 8 Sl. 18 code 1015 — 5% (successor to 194H) |
| Platform 194-O deduction (at source) | Section 8 Sl. 46 code 1058 — 1% (successor to 194-O) |
| Returns credit-note deadline | Section 34 CGST — 30 November following FY of original supply |
The reconciliation in one paragraph
A branded apparel principal shipping across Myntra, Ajio, and Flipkart Fashion runs a Section 9(1) normal supply for every order; issues a tax invoice to the end customer (not to the platform); pays output GST on the gross taxable value; and receives net cash-in from the platform after the platform deducts commission (billed separately at Section 194H code 1015), logistics or shipping (billed by the platform’s logistics arm), returns adjustments (netted per the platform’s return-handling model), Section 194-O TDS at 1% (deducted at source by the platform under Income-tax Act 2025 payment code 1058), and Section 52 TCS at 0.5% (deducted at source and remitted by the platform in GSTR-8 under Notification 15/2024-CT). The brand’s reconciliation must decompose every settlement row into these six components, match each component to its own control book (sales register, commission invoice, TDS working, credit note, 194-O Form 26AS credit, TCS GSTR-2A credit), and close the loop from gross taxable value at order to net cash credit in the bank statement — for every platform, every payout, every quarter.
What the three-platform apparel play looks like in India
The category-defining example is a house of brands running Pantaloons (value department store), Allen Solly (mid-premium men’s and women’s), and Van Heusen (formal and mid-premium menswear) across the three platforms — the shape that Aditya Birla Fashion and Retail (ABFRL) operates. The illustrative principal in this article is a branded-apparel controller running the same three-brand, three-platform shape at Indian scale. The Q3 FY 2026-27 quarterly picture below is representative — public disclosures do not reveal internal settlement values, so cross-verify against your own dispatch register and settlement file before action.
Other tier-1 branded-apparel principals running a materially similar three-platform pattern include Trent Ltd (Westside, Zudio) and Reliance Retail (Reliance Trends, AJIO), though channel mix and captive-platform economics differ for both. Specialist branded-apparel firms operating at scale include Page Industries (Jockey, Speedo), Raymond, Arvind Ltd (Arrow, USPA, Flying Machine on licence), and the many contract-manufacturing and export principals — Shahi Exports, Gokaldas Exports, Pearl Global Industries — who supply into the private-label programmes of the same three ECO platforms and have their own reconciliation surface at the B2B leg upstream of the ECO.
Regional apparel manufacturing feeding the three-platform supply chain sits across Tiruppur (knitwear), Ludhiana (winter knitwear), Karur (home textiles crossover), Surat (man-made fibre and synthetics apparel), Bhilwara (suiting), and Bombay Dyeing’s Solapur-Panipat corridor for home textiles. The brand principal’s reconciliation surface is downstream of all of this — the SKU has already been manufactured, warehoused, and dispatched by the time the Myntra, Ajio, or Flipkart Fashion order fires.
The regulatory overlay — Section 9(1), Section 52 TCS, Section 34 credit notes
Three GST provisions structure the reconciliation.
Section 9(1) CGST — the general levy on normal supply — is the relevant charging provision for online apparel sold through Myntra, Ajio, and Flipkart Fashion. The brand is the seller-of-record. The brand raises the tax invoice to the end customer. The brand pays output GST on the gross taxable value at the applicable rate (5% for apparel priced up to ₹1,000; 12% for apparel priced above ₹1,000 per HSN 6109, 6110, and adjacent codes for knit or woven apparel and made-ups — verify current CBIC notification for the specific SKU). The platform is not the supplier of the goods; it is a Section 52 TCS collector.
Section 9(5) CGST — the deemed-supplier provision — does NOT apply to online apparel. The Government has notified Section 9(5) for only four categories: passenger transport (Ola, Uber), housekeeping services, restaurant and cloud-kitchen services (Zomato, Swiggy dine-in supply), and accommodation services. Apparel and lifestyle goods are not in the Section 9(5) list. Attempting to treat online apparel as a Section 9(5) supply — where the platform pays output GST — leaves the brand in default of Section 9(1) output-GST payment on the same supply and triggers Section 73 or 74 recovery with penalty. The distinction is covered in detail in the Branded apparel reconciliation Section 9(1) vs 9(5) article.
Section 52 CGST — Tax Collection at Source by ECOs — requires every ECO to collect tax at source on the net taxable value of supplies made through it by other suppliers where the ECO collects the consideration. Notification 15/2024-Central Tax dated 10 July 2024 reduced the notified rate from 1% to 0.5% (0.25% CGST plus 0.25% SGST for intra-state; 0.5% IGST for inter-state). The platform remits TCS monthly in Form GSTR-8 by the 10th of the following month. The brand claims the TCS as a credit in its own GSTR-2A after the platform’s GSTR-8 flows through — GSTR-2A visibility follows GSTR-8 filing with a lag of a few days. The brand’s control point is to ensure that (a) the platform is deducting at the notified 0.5% rate (not the legacy 1%), (b) the aggregate TCS claimed matches the aggregate deducted per the settlement files across all three platforms, and (c) the TCS is claimed against the correct GSTIN (state-of-supply matching) rather than being applied to the wrong state’s ledger.
Section 34 CGST — credit and debit notes — governs the tax treatment of returns. When a customer returns an apparel item, the platform reverses the credit to the brand in the next settlement file. The brand must issue a Section 34 credit note to reduce its output GST liability on the returned supply. The credit note must be issued by 30 November following the end of the financial year in which the original supply was made, or the date of furnishing the annual return, whichever is earlier. Returns booked by the platform after this cut-off — say a January 2027 return of a March 2026 supply — cannot reduce the brand’s FY 2025-26 output GST liability. This is the largest silent revenue leakage in ECO apparel reconciliation and is covered in detail in the Returns RTV branded apparel credit note Section 34 article.
Section 8 Sl. 18 code 1015 of the Income-tax Act 2025 — successor to legacy Section 194H — governs TDS on commission or brokerage paid to a resident. The brand deducts 5% TDS on the platform’s commission invoice value at the point of credit or payment, whichever is earlier, and remits it under payment code 1015. Section 8 Sl. 46 code 1058 — successor to legacy Section 194-O — governs TDS on ECO-facilitated payments. The platform deducts 1% TDS at source on the gross sale value credited to the seller-brand. This deduction appears in the brand’s Form 26AS as a credit at the brand’s PAN and reduces the brand’s advance-tax liability. The two TDS flows are distinct — 194H is the brand deducting on the commission bill; 194-O is the platform deducting on the sale credit — and both must be reconciled independently.
A worked example — Q3 FY 2026-27 across three platforms
Illustrative — the following figures represent the operating pattern of a representative three-platform branded-apparel play at Indian scale. Public disclosures do not reveal internal settlement values; cross-verify against your own settlement files and GSTR-8 credits before action.
A branded-apparel principal closes Q3 FY 2026-27 (October to December 2026) with the following aggregate settlement picture across the three platforms.
Myntra — Q3 gross taxable ₹42 crore across approximately 720,000 orders. Category mix skews to men’s mid-premium (Van Heusen shirts and trousers) and women’s ethnic and casual (Allen Solly, Pantaloons private label). Weighted-average commission across categories runs at approximately 18% for this SKU mix. Logistics and shipping charges (billed by Myntra’s logistics arm) run at 3% of gross taxable. Returns booked in Q3 (against Q3 and prior-quarter supplies) run at approximately 24% of forward sales — a fashion-normal return rate for the category. Net-of-commission-and-logistics-and-returns realisation is approximately 22% of gross — leaving ₹32.8 crore of net cash-in before taxes-at-source. Section 194-O TDS at 1% on the gross taxable of ₹42 crore is ₹42 lakh, deducted by Myntra at source and remitted to the government under payment code 1058, appearing in the brand’s Form 26AS. Section 52 TCS at 0.5% on the same gross taxable is ₹21 lakh, deducted and reported by Myntra in GSTR-8, appearing in the brand’s GSTR-2A. Net cash-in from Myntra to the brand’s bank account for the quarter settles at approximately ₹32.8 crore minus (₹42 lakh + ₹21 lakh) = ₹32.17 crore, subject to the T+15 payout cadence pushing the last week’s forward sales into the January 2027 settlement window.
Ajio — Q3 gross taxable ₹18 crore across approximately 380,000 orders. Category mix runs younger and more casual than Myntra. Weighted-average commission runs at approximately 14% on this mix. Logistics and shipping charges are integrated at 2% of gross taxable. Returns net directly against forward sales in the same settlement file at approximately 20% of forward sales. Net-of-commission-and-logistics-and-returns realisation runs at approximately 18% of gross — leaving ₹14.8 crore of net cash-in before taxes-at-source. Section 194-O TDS at 1% on ₹18 crore is ₹18 lakh; Section 52 TCS at 0.5% is ₹9 lakh. Net cash-in from Ajio settles at approximately ₹14.8 crore minus ₹27 lakh = ₹14.53 crore, on the T+7 to T+10 cadence.
Flipkart Fashion — Q3 gross taxable ₹9 crore across approximately 190,000 orders. Category mix runs more value-oriented (Pantaloons private-label heavy). Weighted-average commission runs at approximately 13%. Logistics runs at 3% of gross. Returns run on a separate adjustment schedule at approximately 18% of forward sales. Net realisation runs at approximately 16% of gross — leaving ₹7.56 crore of net cash-in before taxes-at-source. Section 194-O TDS at 1% is ₹9 lakh; Section 52 TCS at 0.5% is ₹4.5 lakh. Net cash-in from Flipkart Fashion settles at approximately ₹7.56 crore minus ₹13.5 lakh = ₹7.42 crore, on the T+7 cadence.
Aggregate three-platform picture for Q3 FY 2026-27:
| Line item | Myntra | Ajio | Flipkart Fashion | Total |
|---|---|---|---|---|
| Gross taxable (₹ crore) | 42.0 | 18.0 | 9.0 | 69.0 |
| Commission and logistics deductions (₹ crore) | 9.24 | 3.24 | 1.44 | 13.92 |
| Net after deductions (₹ crore) | 32.8 | 14.8 | 7.56 | 55.16 |
| Section 194-O TDS at 1% (₹ lakh) | 42.0 | 18.0 | 9.0 | 69.0 |
| Section 52 TCS at 0.5% (₹ lakh) | 21.0 | 9.0 | 4.5 | 34.5 |
| Net cash-in to bank (₹ crore) | 32.17 | 14.53 | 7.42 | 54.12 |
| Settlement cadence | T+15 | T+7 to T+10 | T+7 | mixed |
Commission-invoice and 194H reconciliation. Aggregate platform commission billed across the three platforms for Q3 sits at approximately ₹9.6 crore of taxable value (18% of ₹42cr on Myntra + 14% of ₹18cr on Ajio + 13% of ₹9cr on Flipkart Fashion = ₹7.56cr + ₹2.52cr + ₹1.17cr = ₹11.25cr; net of the ₹1.65cr logistics component embedded, the pure commission bill is approximately ₹9.6cr). The brand deducts Section 194H TDS at 5% under payment code 1015 = approximately ₹48 lakh, remitting it to TRACES against each platform’s PAN. The platform issues a tax invoice for the commission with GST at 18% on the service value; the brand claims ITC on this commission GST in its GSTR-3B after the platform’s invoice appears in the brand’s GSTR-2B.
Section 34 credit-note reconciliation. Returns booked in Q3 against Q3 forward sales are within the same FY and pose no Section 34 timing risk. Returns booked in Q3 against prior-quarter (Q1 or Q2 FY 2026-27) supplies are also within the same FY. The exposure sits in Q4 (January to March 2027) and Q1 FY 2027-28 (April to June 2027) — where returns of Q3 FY 2026-27 supplies must be booked with credit notes issued by 30 November 2027 (the Section 34 cut-off for FY 2026-27 supplies). Returns booked in December 2027 or later cannot recover output GST. The brand’s ageing report on unreturned inventory sitting in platform reverse-logistics warehouses is the leading indicator of Section 34 exposure and must be tracked at the SKU-order level, not the aggregate.
Section 52 TCS reconciliation to GSTR-2A. The brand’s Q3 aggregate TCS credit is ₹34.5 lakh across the three platforms. Each platform files GSTR-8 by the 10th of the following month for the preceding month’s TCS deduction. October TCS appears in November GSTR-2A; November TCS in December GSTR-2A; December TCS in January 2027 GSTR-2A. The brand’s Q3 aggregated TCS credit — ₹34.5 lakh — must match the sum of TCS credits appearing in the brand’s GSTR-2A across October, November, and December months. Mismatches typically arise from (a) the platform filing GSTR-8 late (TCS credit slips into the next month’s GSTR-2A), (b) the platform reporting TCS against a stale GSTIN (post-GSTIN-change scenarios), and (c) the platform mis-classifying inter-state as intra-state (IGST versus CGST+SGST TCS split).
Common reconciliation breakages
Five breakages recur across branded-apparel principals reconciling three-platform ECO settlements, and each maps to a specific control failure.
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Section 9(5) misclassification. A brand controller who has read about Section 9(5) restaurant and cloud-kitchen deemed-supplier notifications sometimes tries to apply the same logic to online apparel. It does not apply. Apparel is not in the Section 9(5) notified list. The brand remains the Section 9(1) supplier and must pay output GST on the gross taxable value. The platform’s Section 52 TCS is a collection mechanism, not a substitution for output GST.
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Return credit-note booked past 30 November. The single largest silent leakage. A brand accepts a January-2027 return of a March-2026 supply commercially — the platform reverses the credit, the brand takes the SKU back into inventory — but the Section 34 credit note cannot be issued (the FY 2025-26 30 November 2026 cut-off has already passed). Output GST on the original supply becomes irrecoverable. Fashion-normal 20-24% return rates compound this exposure at scale.
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194-O deducted-at-source not claimed as advance-tax credit. The platform deducts 1% Section 194-O TDS on gross sale value credited to the brand. This credit appears in Form 26AS at the brand’s PAN and reduces the brand’s advance-tax liability for the quarter. Brands that do not extract 26AS at the right cut-off or that treat 194-O as a fee (rather than an advance-tax credit) over-pay quarterly advance tax and carry the excess forward as a refund claim — an unnecessary working-capital drag.
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TCS rate mismatch — 1% legacy vs 0.5% notified. Notification 15/2024-CT reduced the Section 52 TCS rate from 1% to 0.5% effective 10 July 2024. Platforms that have not updated their tax engine (or that regressed to the legacy rate on a specific settlement file) over-deduct TCS, which slots into GSTR-2A at the higher rate. The brand’s reconciliation platform should assert 0.5% as the expected TCS rate and flag any settlement file at 1% for platform-side correction before GSTR-8 filing.
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Bank narration ambiguity across three platforms. Bank credit narrations for Myntra, Ajio, and Flipkart Fashion payouts share overlapping keywords (all three routing through payment aggregators; narrations sometimes surface the aggregator name rather than the platform name). Reconciliation platforms that cannot distinguish narrations by platform via amount-anchoring against expected T+15 / T+7 / T+7 cadences mis-attribute credits and break the platform-wise net-cash trace.
How a reconciliation platform handles this
A purpose-built apparel ECO settlement reconciliation platform ingests the Myntra, Ajio, and Flipkart Fashion settlement files at their native cadence; decomposes every row into gross taxable, commission (billed and taxable), logistics, returns adjustment, Section 194-O deduction (at source), and Section 52 TCS deduction (at source); matches gross taxable to the brand’s sales register by order ID; matches commission line to the platform’s tax invoice and the brand’s own 194H TDS working under Income-tax Act 2025 payment code 1015; matches returns adjustment to Section 34 credit notes and flags any return where the credit-note issuance is approaching or past the 30 November following-FY cut-off. The platform aggregates Section 52 TCS across all three platforms into a monthly and quarterly ledger and reconciles it against GSTR-2A after each platform files GSTR-8. It reconciles 194-O credits at the brand’s PAN against Form 26AS. It traces net-cash-in from each platform to the specific bank credit narration, using amount-anchoring against the platform-specific cadence to disambiguate overlapping keywords. Match rate improvement from 51 to 88 percent on the order-to-settlement match, combined with ISO 27001:2022 posture and DPDP Act 2023 aligned data handling, is what makes the platform an infrastructure investment rather than a spreadsheet substitute.
Cross-cluster bridges and where to read next
The three-platform apparel settlement discipline in this article connects into several adjacent surfaces. For the Section 9(1) versus Section 9(5) classification discipline, read Branded apparel reconciliation Section 9(1) vs 9(5). For the Section 34 credit-note timing discipline that governs returns, read Returns RTV branded apparel credit note Section 34. For the VMI (Vendor Managed Inventory) reconciliation shape that captive-format fashion retailers such as Trent Ltd (Westside) run on their brand-partner supply chain, read Trent Westside fashion VMI reconciliation. Upstream in the supply chain, the Multi-hop job-work reconciliation for textile manufacturing article covers the yarn-to-garment conversion chain that feeds the SKUs onto the three platforms, and the ITC-04 quarterly return textile job-work reconciliation article covers the ITC-04 filing surface. For adjacent ECO settlement content in other verticals, see the payment-gateway cluster’s Amazon settlement reconciliation, Flipkart settlement reconciliation, and Meesho settlement reconciliation articles. The commercial pillar for the entire textile cluster is Textile reconciliation software India; the broader authority is reconciliation software India.
The five FAQs below address the operational questions Indian branded-apparel controllers ask most often when implementing structured three-platform ECO settlement reconciliation.
- ▸ Section 52, Central Goods and Services Tax Act 2017 — Tax Collection at Source by Electronic Commerce Operators. Every ECO, not being an agent, must collect tax at source at the notified rate on the net value of taxable supplies made through it by other suppliers, where the consideration is collected by the ECO. Notification 15/2024-Central Tax dated 10 July 2024 fixed the intra-state TCS rate at 0.5% (0.25% CGST + 0.25% SGST) and 0.5% for inter-state (IGST), reduced from the earlier 1% ceiling. TCS is remitted monthly and reported in Form GSTR-8 by the ECO.
- ▸ Section 9(1), Central Goods and Services Tax Act 2017 — Levy and collection of central tax. Supply of goods or services or both, except on the supply of alcoholic liquor for human consumption, on the value determined under Section 15 and at rates notified by the Government. Online apparel supplied through Myntra, Ajio, or Flipkart Fashion is a Section 9(1) normal supply by the brand principal; the ECO's role is that of a collecting agent for TCS under Section 52, not a deemed supplier. Section 9(5) deemed-supplier categories notified by the Government are limited to passenger transport, housekeeping, restaurant/cloud kitchen, and accommodation — apparel is not covered.
- ▸ Section 34, Central Goods and Services Tax Act 2017 — Credit and debit notes. Where taxable value or tax charged in a tax invoice is found to exceed the taxable value or tax payable in respect of the supply, or where goods supplied are returned by the recipient, the supplier may issue a credit note. The credit note reducing output tax liability must be issued by 30 November following the end of the financial year in which the original supply was made, or the date of furnishing the annual return, whichever is earlier. Returns booked by the platform after this cut-off cannot reduce the brand's output GST liability.
- ▸ Section 8 Sl. 18 code 1015, Income-tax Act 2025 — TDS on commission and brokerage under the successor to legacy Section 194H. Payment code 1015 applies to commission or brokerage paid to a resident payee at 5%. Commission charged by an ECO platform to the seller-brand is TDS-liable at 5% under this code. The brand also encounters payment code 1058 (successor to Section 194-O, 1% TDS on ECO-facilitated payments) which the ECO deducts on the gross sale value credited to the seller — this appears in the brand's Form 26AS as a credit and reduces the brand's advance-tax liability.