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How-To · 13 min read

Tea Auction Settlement Reconciliation — Kolkata + Coonoor + Guwahati Cornerstone

A tea garden shipping a 100-chest lot from Dibrugarh to Kolkata Tea Auction Centre through a licensed broker must reconcile the garden dispatch note against the bonded warehouse receipt, the broker catalogue lot, the auction prompt at the fall of the hammer, the 15-day settlement to garden bank net of 1 percent broker commission, the warehouse rent debit for days beyond the free-days band, Section 194H code 1015 TDS on the broker commission, Section 194Q on the buyer side above the Rs 50 lakh aggregate threshold, and the Rule 89(5) inverted-duty refund on 5 percent tea output against 18 percent packaging and power inputs.

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Published 13 July 2026
Domain expertise
TDS Reconciliation GST Input Credit Platform Settlements NACH Batch Matching Bank Reconciliation Form 26AS Matching ERP Integrations Enterprise Finance Ops
Knowledge Card
Problem

A tea garden in Assam or the Dooars or the Nilgiris routing production through the Tea (Marketing) Control Order 2003 auction system must reconcile a six-hop consignment cycle across Kolkata, Guwahati, Coonoor, and other licensed auction centres — garden dispatch note against bonded warehouse receipt against broker catalogue against auction prompt (fall of hammer) against 15-day settlement remittance to garden bank net of 1 percent broker commission and warehouse rent debit — while simultaneously computing Section 194H code 1015 TDS at 5 percent on the broker commission, tracking Section 194Q buyer-side purchase code TDS on aggregate above Rs 50 lakh from any single buyer, and filing Rule 89(5) inverted-duty refund claims on 5 percent tea output against 18 percent packaging and power inputs. Manual reconciliation across six hops loses per-lot commission accruals, mis-attributes warehouse rent to the wrong sale-week, under-deducts TDS on broker commission where the garden operates with multiple brokers across centres, and mis-computes Net ITC in the Rule 89(5) formula by including input services or capital goods — exposing the garden and blender to Section 73 or 74 GST notices, Section 201 short-deduction demands, and buyer-side Form 26AS mismatches.

How It's Resolved

Ingest the garden's daily manufacturing register and dispatch note by chest count and grade, match against the auction warehouse's inward receipt at Kolkata, Guwahati, Coonoor, Cochin, Coimbatore, Siliguri, or Jorhat by garden mark and invoice number, and carry the lot-level attributes (chest count, net weight, grade, invoice date) as immutable dimensions through to the broker's catalogue entry. Match the broker's catalogue against the auction prompt and settlement statement (sale number, lot number, weighted average realisation, gross auction value, 1 percent broker commission, net remittance). Feed the settlement statement into the garden's bank inflow reconciliation with a 15-day expected-settlement window. Accrue broker commission by broker PAN across sale-weeks, key to Section 18 Sl. 15 payment code 1015 at 5 percent, and generate the monthly Form 26Q TDS remittance and Form 16A issue schedule. Track buyer-wise aggregate purchase value across the financial year for each garden-buyer pair, flag threshold crossings at Rs 50 lakh, and expose the Section 8 Sl. 8 code 1031 TDS credit expected on the garden's PAN for reconciliation with Form 26AS. Extract packaging input GST at 18 percent and tea output GST at 5 percent from the blender's GSTR-1 and GSTR-3B into the Rule 89(5) refund workbook, apply the Notification 14/2022-amended formula (Net ITC excludes input services and capital goods), and generate the GST RFD-01 filing base every month or quarter. Reconcile the warehouse rent invoice line-by-lot against the garden's catalogue-and-prompt register with free-days credit tracking.

Configuration

Garden master with garden code, plantation area, small tea grower flag, PAN, GSTIN, TAN, and bank account; blending unit master with unit code, GSTIN, e-invoicing threshold flag, and mixed-output position (HSN 0902 packet tea versus HSN 2101 instant tea); auction-centre master with centre code (Kolkata, Guwahati, Coonoor, Cochin, Coimbatore, Siliguri, Jorhat), bonded warehouse network, and sale-week calendar; broker master with broker code, PAN, GSTIN, TDS payment code 1015, and commission rate (standard 1 percent, variations negotiated); buyer master with buyer PAN, TAN, aggregate-purchase running total for the current financial year, and Section 194Q applicability flag; warehouse master with warehouse code, per-chest-per-day rent schedule versioned by effective date, and free-days band per sale-week; grade master (CTC BOPF, PF, D, F, PD; orthodox FTGFOP1, TGFOP, GFOP, FOP); GSTR-1 and GSTR-3B feed for the Rule 89(5) refund workbook; sale-week calendar for auction centres; Section 43B(h) MSME flag on packaging suppliers (many corrugated carton and pouch converters are MSME-registered).

Output

A sale-week and month-end multi-hop tea auction reconciliation pack: garden dispatch register by chest count and grade; bonded warehouse receipt register by lot at each auction centre; broker catalogue and sample-draw register by sale number; auction prompt and settlement register with gross realisation, 1 percent broker commission, net remittance, and 15-day settlement window compliance; broker commission run with code 1015 TDS reconciled against the garden's Form 26Q filing and Form 16A issue log; buyer-wise aggregate purchase register with Section 194Q threshold-crossing flags for each garden-buyer pair; Rule 89(5) inverted-duty refund draft with amended Net ITC formula and packaging plus power input register mapped by tax period; warehouse rent register by lot with free-days credit and per-chest-per-day accrual reconciled against the warehouse rent invoice; year-end summary of Section 43B(h) MSME payment discipline for packaging vendors.

A tea garden manager in Dibrugarh signs off on the daily manufacturing register for the peak second-flush week and dispatches 100 chests — each with a garden mark, an invoice number, a CTC BOPF grade code, and a 45-kilogram net weight declaration — by covered truck to the Contemporary Warehouse at Kolkata. Seven days later the lot is catalogued by J.Thomas & Co as Sale 28 lot 4712; a fortnight after that the auction is held at the Kolkata Tea Auction Centre, the fall of the hammer records a weighted-average realisation of Rs 195 per kilogram against a licensed packet-tea buyer, and a 15-day settlement window commences with the broker as the collection agent. On day 15 the broker remits the auction proceeds to the garden’s bank at Dibrugarh, net of a 1 percent broker commission, and issues a service invoice to the garden for the commission with 18 percent GST that the garden processes for Section 194H code 1015 TDS at 5 percent. Two days later the Kolkata bonded warehouse issues a separate rent invoice at Rs 12 per chest per day for the fourteen days the lot sat at warehouse beyond the 21-day free-days band. This is tea auction settlement reconciliation Kolkata Coonoor Guwahati at operating scale, and the discipline that keeps the garden’s Section 65 GST audit, the blender’s Rule 89(5) inverted-duty refund cycle, and the buyer’s Section 194Q Form 26AS credit simultaneously clean is what separates a well-run auction-marketed garden from one that spends four months of the following financial year reconciling a sale-week broker statement against warehouse rent debits and buyer-side TDS credits.

Quick reference

AspectDetail
Governing marketing frameworkTea (Marketing) Control Order 2003, notified under the Tea Act 1953
RegulatorTea Board of India, under Ministry of Commerce and Industry
Primary auction centresKolkata, Guwahati, Coonoor
Additional licensed centresCochin, Coimbatore, Siliguri, Jorhat
Registered brokersJ.Thomas & Co, Contemporary Brokers, Carritt Moran, Paramount Tea Marketing, Forbes Ewart & Figgis
Broker commission1 percent standard, retained from auction realisation
Settlement window15 days from fall of hammer (prompt)
Free-days bandTypically 21 days at bonded warehouse (varies by centre and sale-week)
Tea output GST5 percent (HSN 0902 bulk and packet tea, whether or not flavoured)
Instant tea output GST18 percent (HSN 2101 instant tea, concentrate, premix)
Packaging input GST18 percent (HSN 4819 cartons, HSN 3923 polymer pouches and laminates, HSN 4802 kraft paper, HSN 7607 aluminium foil)
Broker commission TDSSection 18 Sl. 15 code 1015 — 5 percent
Buyer-side purchase TDSSection 8 Sl. 8 code 1031 — 0.1 percent on aggregate above Rs 50 lakh
GST refund provisionSection 54(3) CGST with Rule 89(5) as amended by Notification 14/2022
Supreme Court anchorUnion of India v. VKC Footsteps (2021) 10 SCC 674
Refund filing formGST RFD-01, monthly or quarterly
Standard tea chestApproximately 45 kilograms net weight

The reconciliation in one paragraph

The Indian tea auction system routes a specified share of estate production through licensed auction centres at Kolkata, Guwahati, Coonoor, Cochin, Coimbatore, Siliguri, and Jorhat under the Tea (Marketing) Control Order 2003 administered by the Tea Board of India. A garden dispatches manufactured tea in standard chests or sacks to a bonded warehouse at the chosen auction centre; the warehouse issues a warehouse receipt; a Tea Board-registered broker (J.Thomas & Co, Contemporary Brokers, Carritt Moran, Paramount Tea Marketing, or Forbes Ewart & Figgis) draws a sample, catalogues the lot into an upcoming numbered sale, and sends samples plus catalogue extracts to registered buyers ahead of the auction; the auction is held and the fall of the hammer is the legal prompt that transfers title and starts the 15-day settlement clock. The buyer remits the auction realisation to the broker within the prompt period; the broker remits to the garden net of a 1 percent commission and issues a service invoice for the commission with 18 percent GST. The garden deducts Section 18 Sl. 15 code 1015 TDS at 5 percent on the commission accrual, keyed to the broker’s PAN, and remits on Form 26Q. Where a single buyer’s aggregate purchases from the garden cross Rs 50 lakh in a financial year, the buyer deducts Section 8 Sl. 8 code 1031 TDS at 0.1 percent on the excess, credited to the garden’s PAN through Form 26AS. The auction warehouse charges rent on a per-chest-per-day basis for days beyond the free-days band and issues a separate rent invoice with 18 percent GST. On the downstream packet-tea leg, the blender’s 5 percent output tea against 18 percent packaging and power input creates a Rule 89(5) inverted-duty refund cycle filed on Form GST RFD-01 under the Notification 14/2022-amended formula.

What the scenario looks like in India

The Indian tea industry runs a highly institutionalised marketing chain around a small number of licensed auction centres and a small number of Tea Board-registered brokers. Kolkata is the largest auction centre by volume and the primary marketing route for Assam and Dooars gardens; Guwahati sits at the head of the North Bank Assam catchment and is the secondary route for many Assam gardens; Coonoor is the primary auction centre for the Nilgiris (South India) catchment. Cochin serves Kerala and Karnataka gardens, Coimbatore serves southern gardens including some Nilgiris volume, Siliguri handles Darjeeling and Terai teas, and Jorhat provides an alternative Assam route.

Illustrative brands running the packet-tea and blending downstream leg at the scale relevant to this reconciliation include Tata Consumer Products (Tetley and Tata Tea, listed), Wagh Bakri Tea Group (unlisted but the second-largest Indian packet-tea brand), Goodricke Group (listed, plantation and packet), Jay Shree Tea (listed, plantation and packet), McLeod Russel India (listed, the largest bulk tea producer in the world by area), Rossell Tea, and the Assam Company. Coffee-side blenders that also handle tea in some product lines include CCL Products (listed, world instant-coffee B2B) and Hindustan Unilever (Bru brand, listed) — for the packet-tea buying side, HUL runs a Brooke Bond and Red Label programme historically anchored on the auction system.

Regional geography dictates the operating template. Assam gardens in Dibrugarh, Jorhat, and Golaghat districts predominantly route to Kolkata or Guwahati; Dooars and Terai gardens in West Bengal route to Kolkata or Siliguri; Darjeeling gardens (small volumes, high value, often direct-shipment for the export orthodox segment rather than auction) route to Siliguri when the auction is used; Nilgiris gardens in Coonoor, Ooty, and adjacent hill blocks route to Coonoor or Coimbatore; Kerala gardens in Wayanad and Idukki route to Cochin or Coimbatore. Small tea growers (STGs) — a category the Tea Board formally recognises for plantations below 25 acres — feed their green leaf into bought-leaf factories (BLFs) that manufacture the made tea and then route it into the auction chain in the BLF’s name, adding an intermediate purchase-and-processing hop before the auction hop.

The auction-hop discipline is highly repetitive and highly documented — the sale-week calendar is published in advance across all centres, each sale has a numbered slot (Sale 1 through Sale 52 across the year), each lot is uniquely catalogued with a garden mark plus a lot number, and each broker maintains an audit trail of catalogue extracts, sample-cup notes, and buyer bid records. The reconciliation base case therefore has the strongest institutional documentation of any Indian agri-commodity chain, and the failure modes are almost always at the intersection of documentation surfaces — where the broker statement diverges from the warehouse rent invoice, where the buyer’s Section 194Q credit does not appear in the garden’s Form 26AS, or where the packet-tea blender’s Rule 89(5) refund draft under-computes Net ITC because input services have been left in the numerator.

The regulatory overlay — Tea (Marketing) Control Order, Section 194H, Section 194Q, and Rule 89(5)

Four regulatory anchors govern the tea auction cycle and the downstream blending leg, and each maps to a distinct reconciliation surface.

The Tea (Marketing) Control Order 2003, notified by the Ministry of Commerce and Industry under the Tea Act 1953, is the marketing-side framework. The order mandates auction as the primary marketing route for a specified share of estate production, licenses the auction centres at Kolkata, Guwahati, Coonoor, Cochin, Coimbatore, Siliguri, and Jorhat, and prescribes the qualification and registration regime for brokers, buyers, and warehousekeepers. The Tea Board of India — a statutory body under the Ministry of Commerce and Industry — administers the order and maintains the register of licensed producers, brokers, buyers, and warehousekeepers. Compliance with the order is a precondition for participation in the auction chain and the reconciliation surface at the garden end is the estate’s Tea Board registration certificate, the sale-week calendar, and the auction-centre catalogue reference for every lot dispatched.

Section 18 Sl. 15 code 1015 of the Income-tax Act 2025 (successor to legacy Section 194H) governs TDS on the broker commission. The 1 percent broker commission retained from the auction realisation is a service fee payable by the garden (principal-producer) to the broker (agent). The garden as deductor accrues the commission as an expense, keys the accrual to the broker’s PAN, deducts TDS at 5 percent on Form 26Q, remits to TRACES against the broker’s PAN, and issues Form 16A within the statutory timeline. Where the garden operates with multiple brokers across centres — Kolkata via J.Thomas, Guwahati via Contemporary, Coonoor via Forbes Ewart & Figgis, for example — the broker commission register carries a broker-code dimension and each broker’s PAN sits in the deductee master. Mis-classification (deducting under code 1023/1024 as though the broker were a contractor, or forgetting to deduct on the grounds that the commission is netted from the remittance rather than paid separately) is the most common Form 26AS mismatch on the broker side and typically surfaces at the broker’s own statutory audit when the auditor cross-checks Form 26AS credit against the broker’s service-invoice output.

Section 8 Sl. 8 code 1031 of the Income-tax Act 2025 (successor to legacy Section 194Q) governs TDS on the buyer side. Where a buyer’s turnover in the preceding financial year exceeded Rs 10 crore, and the aggregate value of purchase from a single resident seller in the current financial year crosses Rs 50 lakh, the buyer deducts TDS at 0.1 percent on the value in excess of Rs 50 lakh at the time of credit or payment (whichever is earlier). In the tea auction chain this typically triggers at large packet-tea processors and export houses that concentrate purchases at a small set of large gardens across a season. The buyer’s deduction is credited against the garden’s PAN through Form 26AS in the following filing quarter; the garden’s own reconciliation must therefore track a buyer-wise aggregate-purchase running total for each buyer-garden pair and flag threshold crossings so the Form 26AS credit is reconciled and any short-credit or over-credit is caught early.

Section 54(3) of the CGST Act 2017 permits a registered person to claim a refund of unutilised ITC where the credit has accumulated on account of the rate of tax on inputs being higher than the rate of tax on output supplies — the inverted duty structure. Rule 89(5) of the CGST Rules 2017, as amended by Notification 14/2022-Central Tax dated 5 July 2022, provides the operational formula. Maximum Refund Amount = (Turnover of inverted-rated supply of goods and services × Net ITC / Adjusted Total Turnover) minus (Tax payable on such inverted-rated supply × Net ITC / ITC availed on inputs and input services). Net ITC excludes input services and capital goods per the amendment; the Supreme Court in Union of India v. VKC Footsteps India Pvt Ltd (2021) 10 SCC 674 upheld this exclusion. For tea, the inversion arises structurally because tea under HSN 0902 (whether the bulk tea sold by the garden at auction or the packet tea sold to modern trade) attracts 5 percent output GST, and the packaging inputs (HSN 4819 corrugated cartons, HSN 3923 polymer pouches and laminates, HSN 4802 kraft paper, HSN 7607 aluminium foil, HSN 4823 printed cartons) plus power drawn from a distribution licensee all attract 18 percent input GST. The packet-tea blender files GST RFD-01 monthly or quarterly against the accumulated inverted-duty credit. Unlike Chapter 15 edible oil — carved out of the refund route by Notification 09/2022-Central Tax — tea under Chapter 9 remains eligible and the refund cycle is live.

A worked example — a Dibrugarh garden, a Kolkata auction, and a packet-tea blender

Illustrative — the following figures represent the operating pattern of a mid-scale Assam garden routing production through the Kolkata Tea Auction Centre via a Tea Board-registered broker. Auction realisations vary substantially by grade, sale-week, orthodox versus CTC segment, and prevailing demand; cross-verify against your own auction catalogue and broker statement before action.

An Assam garden with a manufacturing unit at Dibrugarh dispatches a lot of 100 chests of CTC BOPF grade tea, each chest at 45 kilograms net weight, aggregating to 4,500 kilograms (4.5 metric tonnes). The lot is despatched by road under an invoice raised by the garden to the Tea Board-licensed Contemporary Warehouse at Kolkata; the warehouse issues a warehouse receipt against the invoice; the garden nominates J.Thomas & Co as the auction broker.

J.Thomas draws a chest-level sample, cups and tastes the lot, and catalogues it into the upcoming numbered sale as Sale 28 lot 4712 with a description code covering grade (BOPF), garden mark, and net weight. The auction is held at the Kolkata Tea Auction Centre on the scheduled sale-week day; at the fall of the hammer the weighted-average realisation is Rs 195 per kilogram against a licensed buyer. The gross auction value is 4,500 kilograms times Rs 195 per kilogram equals Rs 8.775 lakh.

The garden’s tea supply is invoiced under HSN 0902 at 5 percent GST. Output GST on the auction sale is Rs 8.775 lakh times 5 percent equals Rs 43,875 (CGST plus SGST for a same-state auction, or IGST for an inter-state transaction). The buyer remits the gross auction value to J.Thomas within the 15-day settlement window commencing from the fall-of-hammer prompt.

J.Thomas retains a 1 percent broker commission on the gross auction value — Rs 8,775 — as its service fee. On day 15 (or the earliest banking day thereafter), J.Thomas remits the net proceeds to the garden’s bank at Dibrugarh: Rs 8,77,500 gross minus Rs 8,775 broker commission equals Rs 8,68,725 net (before any additional agreed adjustments such as sale-specific catalogue charges). J.Thomas separately issues a service invoice to the garden covering the Rs 8,775 commission with 18 percent GST — Rs 1,579.50 — bringing the gross commission invoice to Rs 10,354.50. The garden avails the input GST of Rs 1,579.50 as ITC in the same period.

The garden then processes the broker commission for TDS. Section 18 Sl. 15 code 1015 applies at 5 percent to commission or brokerage payments. The garden deducts TDS at 5 percent on the commission base of Rs 8,775 — Rs 438.75 — on the monthly Form 26Q filing keyed to J.Thomas’s PAN. TDS is remitted to TRACES against J.Thomas’s PAN and Form 16A is issued within the statutory timeline for the quarter.

Where the buyer’s aggregate purchases from the garden across the financial year cross Rs 50 lakh, Section 8 Sl. 8 code 1031 applies at 0.1 percent on the excess. If, for example, the same buyer has purchased Rs 55 lakh from the garden across earlier sales in the financial year, the incremental Rs 5 lakh above the threshold attracts TDS of Rs 500. The buyer deducts this at the time of credit or payment and remits against the garden’s PAN. The garden reconciles the deduction as a Form 26AS credit in the following filing quarter.

Twenty-one days after despatch the lot is auctioned and cleared; the Kolkata Contemporary Warehouse issues a rent invoice for the 14 days the lot sat at warehouse beyond the 21-day free-days band (the total 35 days between despatch-arrival and buyer-clearance minus the 21-day free window). At an illustrative rate of Rs 12 per chest per day, the warehouse rent debit is 100 chests times Rs 12 times 14 days equals Rs 16,800 base, plus 18 percent GST of Rs 3,024, bringing the gross warehouse invoice to Rs 19,824. The garden posts the rent as a period expense, avails the input GST of Rs 3,024 as ITC, and reconciles the invoice line-by-lot against the garden’s own catalogue-and-prompt register.

The downstream packet-tea leg — where a blender such as Tata Consumer or Wagh Bakri buys the bulk auction lot, blends it with other origin teas, packs it under a consumer SKU (250-gram polymer pouch, 500-gram carton, 1-kilogram tin), and sells it through modern trade — sits on the same HSN 0902 output at 5 percent. If the blender’s monthly packet-tea output for the SKU is Rs 100 crore at 5 percent output GST (Rs 5 crore) and the packaging and power input GST for the same period is Rs 12 crore at 18 percent (Rs 216 crore across all input GST, but Rs 2.16 crore attributable to the same SKU as its allocated share), the differential of approximately Rs 1 to Rs 2 crore of ITC accumulates as inverted-duty credit per month. Under the Notification 14/2022-amended Rule 89(5) formula (Maximum Refund = (Turnover of inverted-rated supply × Net ITC / Adjusted Total Turnover) minus (Tax payable on inverted-rated supply × Net ITC / ITC availed on inputs and input services)), the blender files Form GST RFD-01 monthly against the accumulated credit. Net ITC excludes input services (freight, machine maintenance, distributor commission) and capital goods (packaging machinery, blending plant), so the numerator carries only the raw-material, packaging, and utility input GST net of the excluded categories.

Common reconciliation breakages

Five breakages recur across gardens, brokers, blenders, and export houses operating the Indian tea auction chain, and each maps to a specific control failure.

  • Broker commission netting versus separate invoicing. Some gardens treat the broker commission as a net-off on the settlement statement (broker retains 1 percent and remits the balance) and forget that the 1 percent is a service payment attracting Section 194H code 1015 TDS at 5 percent regardless of whether cash moves in one direction or two. The correct treatment is (a) accrue commission expense, (b) deduct TDS on the accrual, (c) remit TDS separately, and (d) receive net remittance from broker; the broker separately issues a service invoice for the commission with 18 percent GST. Gardens that skip the accrual and TDS steps under-deduct TDS by the full 5 percent and expose themselves to Section 201 short-deduction demands.

  • Warehouse rent free-days clock reset error. Where a lot is withdrawn from a sale unsold and re-catalogued for a following sale-week, the free-days clock does not reset — the rent liability keeps accruing on the same lot. Gardens that assume a clock reset understate warehouse rent liability at month-end, and the warehouse’s own reconciliation invoice at the sale-week close then produces a surprise debit that the garden’s operating team has to reconcile after the event.

  • Buyer-side Section 194Q Form 26AS mismatch. Where a single buyer’s aggregate purchases from the garden cross Rs 50 lakh, the buyer must deduct TDS at 0.1 percent on the excess and credit against the garden’s PAN. Buyers that fail to track the running aggregate across the financial year miss the threshold crossing and under-deduct; buyers that over-deduct (deducting on the full purchase value rather than the excess) over-credit against the garden’s PAN. The garden’s reconciliation surface is a buyer-wise aggregate-purchase running total that flags the threshold crossing and reconciles Form 26AS credit against the buyer’s TDS return line.

  • Rule 89(5) Net ITC over-inclusion. Some packet-tea blenders continue to include input services (freight from the auction warehouse to the blending unit, distributor commission, machine maintenance) and capital-goods ITC (packaging machinery, blending plant, cold storage) in the Net ITC numerator of the Rule 89(5) formula. Notification 14/2022 and the Supreme Court in VKC Footsteps have expressly excluded input services and capital goods from Net ITC. The excess claim is either rejected at the proper officer’s scrutiny or partly disallowed after audit, and the disallowed excess triggers Section 74 penalty exposure. Reconciliation discipline requires the input-services and capital-goods ledgers to be separated at source so the Net ITC ratio in the refund formula draws only from the eligible base.

  • Mixed-output apportionment error at instant-tea and packet-tea processors. A processor producing both packet tea under HSN 0902 (5 percent output) and instant tea, tea concentrate, or tea premix under HSN 2101 (18 percent output) runs a mixed-output GST position. Input ITC must be apportioned between the inverted-duty SKU (packet tea) and the neutral-rated SKU (instant tea) at the level required by the ITC apportionment rules. Processors that treat the entire input ITC as attributable to the inverted-duty SKU over-claim the Rule 89(5) refund; processors that leave the apportionment unstructured lose the refund on the packet-tea leg entirely. The reconciliation surface is an HSN-level output register with an apportionment key that maps every input invoice to the appropriate SKU family.

How a reconciliation platform handles this

A purpose-built tea auction reconciliation platform ingests the garden’s daily manufacturing and dispatch register, the bonded warehouse’s inward-receipt register at each auction centre, the broker’s catalogue and sample-draw log by sale number, the auction prompt and settlement statement, the buyer’s remittance, the broker’s commission service-invoice, the warehouse’s rent invoice, and — on the downstream blending leg — the blender’s GSTR-1 and GSTR-3B extract — and produces a per-lot chain view that closes the loop from garden invoice to auction prompt to broker net remittance to garden bank inflow. The platform matches lot-level attributes (garden mark, chest count, grade, net weight) across the six hops of the cycle, tracks the 15-day settlement window against actual bank inflow with variance alerts, accrues broker commission by broker PAN across sale-weeks, keys each accrual to Section 18 Sl. 15 code 1015 for TDS reconciliation, and generates the Form 26Q filing base and Form 16A issue schedule. It tracks buyer-wise aggregate-purchase running totals across the financial year, flags Section 194Q threshold crossings, and reconciles expected buyer-side TDS credit against the garden’s Form 26AS. On the blending leg the platform extracts the 18 percent packaging and power input GST from GSTR-3B and the 5 percent tea output GST from GSTR-1, apportions between HSN 0902 packet tea and HSN 2101 instant tea where the processor runs a mixed-output position, applies the Notification 14/2022-amended Rule 89(5) formula with input services and capital goods correctly excluded from Net ITC, and generates the GST RFD-01 refund draft every month or quarter. Match rate improvement of 51 to 88 percent on the dispatch-to-settlement chain, combined with an ISO 27001:2022 posture and DPDP Act 2023 aligned data handling, is what makes the platform an infrastructure investment for a large plantation group, a Tea Board-registered broker house, or a packet-tea blender rather than a spreadsheet substitute.

The consignment-auction discipline in this article sets up the entire tea and coffee sub-cluster within Agro Processing. For the master view of how tea, coffee, dairy, sugar, edible oil, fertilizer, agrochemical, seed, and rice cluster reconciliation surfaces relate across the Agro Processing family, read the Agro processing reconciliation India — nine sub-verticals master. The Rule 89(5) inverted-duty refund mechanic in this article is structurally identical to the dairy inversion — 5 percent output against 18 percent packaging input — and the mechanics are unpacked in Dairy inverted-duty refund under Rule 89(5) post GST 2.0. The contrast case — where the inverted-duty refund is expressly blocked by notification — is unpacked in Edible oil Chapter 15 IDR refund blocked under Notification 09/2022. Tea and coffee move heavily into export markets under the same RoDTEP and e-BRC infrastructure that governs basmati rice export; the mechanics are unpacked in Basmati rice export reconciliation — MEP and RoDTEP. For the tea packet-tea modern-trade downstream leg where the auction bulk-tea becomes a consumer SKU, read the sibling Wagh Bakri tea packet modern trade reconciliation. For the international tea brand-export leg where a Tata Consumer Tetley SKU crosses the FoB line, read the sibling Tata Consumer Tetley global tea recon — brand export. The commercial pillar for the entire agro sub-cluster is Agro processing reconciliation software India; the broader authority is reconciliation software India.

The five FAQs below address the operational questions Indian tea garden controllers, broker-house finance leads, and packet-tea processor CFOs ask most often when implementing structured multi-hop auction-cycle reconciliation.

Terra Insight
Terra Insight Editorial Team Reconciliation Infrastructure

Content authored by practitioners with experience at Amazon India, Intuit QuickBooks, and the Tata Group. Meet the team →

Published 13 July 2026
Domain expertise
TDS Reconciliation GST Input Credit Platform Settlements NACH Batch Matching Bank Reconciliation Form 26AS Matching ERP Integrations Enterprise Finance Ops
Primary reference: Tea Board of India — for the Tea (Marketing) Control Order 2003, licensed auction centres, registered broker list, and estate registration provisions governing the consignment-auction cycle.
Primary sources cited
Last reviewed against sources on 13 July 2026
  • Tea (Marketing) Control Order 2003, notified under the Tea Act 1953 — Regulatory framework for the marketing of tea in India. Mandates auction as the primary route to market for a specified percentage of estate production, licensed auction centres (Kolkata, Guwahati, Coonoor, Cochin, Coimbatore, Siliguri, Jorhat), registered broker qualification, bonded warehousing arrangements, catalogue and sample discipline, and the fall-of-hammer prompt as the settlement anchor. The Tea Board of India administers the order and maintains the register of licensed producers, brokers, buyers, and warehousekeepers.
  • Section 18 Sl. 15 code 1015, Income-tax Act 2025 (successor to legacy Section 194H) — TDS on commission or brokerage. Code 1015 applies at 5 percent to any commission or brokerage payable by a resident to a resident other than commission for insurance or securities brokerage under separate codes. The 1 percent broker commission retained by a licensed tea broker from the auction realisation on behalf of the garden falls under code 1015. The garden as the deductor keys the broker's PAN, computes TDS on the commission accrual, remits to TRACES against the broker's PAN, and issues Form 16A within the statutory timeline.
  • Section 8 Sl. 8 code 1031, Income-tax Act 2025 (successor to legacy Section 194Q) — TDS on purchase of goods by a buyer whose turnover in the preceding financial year exceeded Rs 10 crore, where the aggregate value of purchase from a resident seller in the current year exceeds Rs 50 lakh. TDS at 0.1 percent on the value in excess of Rs 50 lakh. Applies to the packet-tea processor or the export-house buyer that purchases auction lots aggregating above the threshold from a single garden across a financial year. The buyer's TDS is credited against the garden's PAN and reconciled through the garden's Form 26AS.
  • Section 54(3) Central Goods and Services Tax Act 2017 with Rule 89(5) CGST Rules 2017 as amended by Notification 14/2022-Central Tax — Refund of unutilised input tax credit accumulated on account of the inverted duty structure. Rule 89(5) provides the formula: Maximum Refund = (Turnover of inverted-rated supply × Net ITC / Adjusted Total Turnover) minus (Tax payable on inverted-rated supply × Net ITC / ITC availed on inputs and input services). Net ITC excludes input services and capital goods per the 5 July 2022 amendment. Tea under HSN 0902 attracts 5 percent output GST; packaging inputs under HSN 4819 corrugated cartons, HSN 3923 polymer pouches and laminates, HSN 4802 kraft paper, and power at 18 percent create the inverted-duty exposure. Unlike Chapter 15 edible oil, tea is not carved out of the refund route and the Section 54(3) claim remains live.
  • HSN 0902 Chapter 9 tea rate notification, GST Council rate schedule — Tea under HSN 0902 whether or not flavoured attracts 5 percent GST on garden and blender output supply. Instant tea, tea concentrate, and tea premix under HSN 2101 attract 18 percent output GST. The rate differential between HSN 0902 packet tea at 5 percent and HSN 2101 instant tea at 18 percent creates two structurally different refund positions for the same industry — the packet-tea blender runs a permanent inverted-duty refund cycle; the instant-tea processor runs a neutral or positive output-tax position.
  • Tea Act 1953 read with Tea Development and Promotion Scheme — Statutory anchor for the Tea Board of India as the promotional and regulatory body under the Ministry of Commerce and Industry. Estate registration, plantation area declaration, small tea grower registration, orthodox tea subsidy, quality upgrade support, and export promotion sit under the Tea Development and Promotion Scheme administered by the Tea Board. Reconciliation surfaces at estate level for area-linked subsidy claims and at export level for orthodox tea incentive claims.

Frequently Asked Questions

How does the tea consignment-auction cycle move from garden dispatch to auction settlement across Kolkata, Coonoor, and Guwahati?
The cycle has six distinct hops and each hop is a distinct reconciliation surface. First, the garden's manufacturing unit fires the daily rotorvane or CTC (Crush Tear Curl) or orthodox line and packs the made tea into standard chests, sacks, or paper sacks — each with a garden mark, an invoice number, a grade code (BOPF, PF, D, F, PD for CTC; FTGFOP1, TGFOP, GFOP, FOP for orthodox), and a net weight declaration. Second, the garden dispatches the lot by road (Assam or Dooars gardens to Kolkata; Nilgiris gardens to Coonoor) or by transport network to the auction centre's bonded warehouse — Contemporary Warehouse or a Tea Board licensed warehouse at Kolkata, similar arrangements at Guwahati and Coonoor. Third, the warehouse issues a warehouse receipt against the garden's invoice; the broker of choice (J.Thomas & Co, Contemporary Brokers, Carritt Moran, Paramount Tea Marketing, or Forbes Ewart & Figgis for the southern centres) is nominated by the garden. Fourth, the broker draws a sample lot from the chest sacks, cups and tastes, catalogues the lot into the upcoming sale (Sale 28, Sale 29, and so on by numbered sale-week), and sends the sample plus catalogue extract to registered buyers ahead of the auction. Fifth, the auction is held physically or on the pan-India Bharat Tea Auction platform; the fall of the hammer is the legal prompt at which title transfers and the 15-day settlement window commences. Sixth, the buyer remits the auction realisation to the broker within the prompt period; the broker remits to the garden net of the 1 percent broker commission (and net of any additional deductions the garden and broker have agreed contractually) within the same or a slightly staggered window. Warehouse rent for days beyond the specified free-days band accrues to the garden's account and is invoiced separately by the warehouse.
Why does the broker commission attract Section 194H code 1015 TDS at 5 percent and who is the deductor?
Section 194H of the Income-tax Act 1961 — codified as Section 18 Sl. 15 payment code 1015 in the Income-tax Act 2025 — applies TDS at 5 percent to any commission or brokerage payment by a resident to a resident. The licensed tea broker acts as the agent of the garden (as principal-producer) in the auction-marketing chain; the 1 percent commission the broker retains from the auction realisation is a service fee to the garden for cataloguing, sampling, tasting, market-making, and settlement collection services. The garden is therefore the deductor and the broker is the deductee. In operational practice, the broker's monthly statement to the garden shows the auction realisation on each lot, the 1 percent commission retained, and the net remittance. The garden must (a) accrue the commission as an expense in the same period, (b) key the accrual to the broker's PAN, (c) deduct TDS at 5 percent on the commission on Form 26Q, (d) remit the TDS to TRACES against the broker's PAN, and (e) issue Form 16A within the statutory timeline. Cash movement is one-way from broker to garden (net of commission); TDS is remitted separately by the garden. The reconciliation surface is a broker commission register keyed to broker PAN across each sale-week, matched against the broker's own service-invoice output and the garden's Form 16A issue schedule. Where the garden operates with multiple brokers across Kolkata, Guwahati, Coonoor, Cochin, and other centres — many large gardens do exactly this to diversify counterparty risk and market coverage — the broker commission register carries a broker-code dimension and each broker's PAN sits in the deductee master.
When does Section 194Q code 1031 apply on the buyer side of the tea auction cycle?
Section 194Q — codified as Section 8 Sl. 8 payment code 1031 — applies where a buyer (packet-tea processor, blender, or export house) whose turnover in the preceding financial year exceeded Rs 10 crore purchases goods from a resident seller (a tea garden) and the aggregate value of purchase from that single seller in the current financial year crosses the Rs 50 lakh threshold. Where the threshold is crossed, the buyer must deduct TDS at 0.1 percent on the value in excess of Rs 50 lakh at the time of credit or payment, whichever is earlier. In the tea auction context this typically triggers at large packet-tea processors and export houses that concentrate purchases at a small set of large gardens — a Tata Consumer packet-tea buying centre sourcing from a specific Assam garden, a Wagh Bakri buying centre sourcing from a specific Dooars garden, or an export house consolidating a specific orthodox garden's output. The buyer's deduction is credited against the garden's PAN and appears in the garden's Form 26AS in the following filing quarter. The garden's own accounting reconciles auction realisation net of broker commission, net of warehouse rent, net of buyer-side Section 194Q TDS (which is a credit on the garden's PAN, not a cash deduction from the broker's remittance) and any other agreed adjustments. Section 206C(1H) (buyer-collection TCS on purchase of goods) does not apply where 194Q is being deducted — the deduction takes precedence.
How does the Rule 89(5) inverted-duty refund cycle work for a packet-tea processor at 5 percent output against 18 percent packaging and power inputs?
Tea under HSN 0902 — whether the bulk-tea sold at auction by the garden or the packet tea sold by the blender to modern trade — attracts 5 percent GST on the output supply. The packaging inputs that a packet-tea blender uses to convert bulk-tea into consumer SKUs — corrugated cartons under HSN 4819, polymer laminate pouches under HSN 3923, kraft paper wrappers under HSN 4802, aluminium foil under HSN 7607, printed cartons under HSN 4823, HDPE sacks under HSN 3923 — all attract 18 percent input GST. Additionally, power drawn from a distribution licensee (whether the state electricity utility or a captive solar generator invoiced at commercial slab) attracts 18 percent GST on many industrial consumption slabs, and fuel inputs such as pipeline natural gas or LPG for the blending and roasting operations also attract higher-rate input GST. The 13 percentage-point differential (between 18 percent packaging and power input and 5 percent tea output) accumulates as unutilised ITC in the electronic credit ledger every tax period. Section 54(3) of the CGST Act 2017 permits refund of unutilised ITC on account of the inverted duty structure; Rule 89(5) provides the formula (Maximum Refund = (Turnover of inverted-rated supply × Net ITC / Adjusted Total Turnover) minus (Tax payable on inverted-rated supply × Net ITC / ITC availed on inputs and input services)). Notification 14/2022-Central Tax dated 5 July 2022 amended the second-limb ratio and clarified that Net ITC excludes input services and capital goods; the Supreme Court in Union of India v. VKC Footsteps India Pvt Ltd (2021) 10 SCC 674 upheld this exclusion. Unlike Chapter 15 edible oil — which was expressly carved out of the refund route by Notification 09/2022-Central Tax — tea under Chapter 9 remains eligible. The packet-tea blender files Form GST RFD-01 monthly or quarterly against the accumulated inverted-duty credit. The instant-tea segment under HSN 2101 attracts 18 percent output GST; a processor producing both packet tea (HSN 0902) and instant tea (HSN 2101) runs a mixed-output position and must apportion input ITC accordingly.
What warehouse rent and free-days mechanics govern the bonded warehouse hop, and how does that flow into the garden's reconciliation?
The auction warehouse — whether the Tea Board-licensed bonded warehouse at Kolkata, Guwahati, Coonoor, or Cochin, or a Contemporary Warehouse operated by a Tea Board-approved operator — provides a specified free-days window during which the garden's lot may sit at the warehouse without rent accrual (typically calibrated to allow cataloguing, sample drawing, auction hold, and post-prompt buyer collection). Beyond the free-days window, warehouse rent accrues per chest per day at a schedule the warehouse publishes and updates periodically. Where a lot is withdrawn from a sale unsold and re-catalogued for the following sale-week, the free-days clock does not reset — the garden's rent liability keeps accruing. Where the buyer collects late (within the prompt but at the tail end of the settlement window), the collection-side rent typically transfers to the buyer's account per the buyer's own broker relationship. The warehouse issues a rent invoice with 18 percent GST to the garden covering the rent-accrual for the sale-week; the garden posts the rent as a period expense, avails the 18 percent input GST as ITC (subject to the Rule 89(5) inverted-duty refund cycle), and reconciles the rent invoice line-by-lot against the garden's own catalogue-and-prompt register. The reconciliation surface is a warehouse rent register keyed to lot number, chest count, days at warehouse, free-days credit, and the warehouse's per-chest-per-day rate for the sale-week.

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