Salary
- TDS is required only at the time of payment.
- If the employee opts out of default Sec 115BAC taxation and submits a declaration, deduct under normal rates; otherwise use Sec 115BAC by default.
- Consider other income, deductions, and TDS/TCS when the employee furnishes evidence. Losses other than house property losses are ignored.
- Employer-borne tax on non-monetary perquisites is not deducted from salary, is disallowed to the employer u/s 40(a)(v), is exempt for the employee u/s 10(10CC), and is treated as TDS credit.
- Employee may furnish previous employer salary and TDS details to the current employer.
- Partner salary is not covered u/s 192; from April 1, 2025, it falls u/s Sec 194T if over ₹20,000.
- Direct tips to waiters are not salary and do not require TDS, even if routed through employer credit-card billing (ITC Ltd, 2016 SC).
Accumulated balance/Premature withdrawal of PF
- TDS is deducted only at the time of payment.
- No TDS is required if the aggregate payment is less than ₹50,000.
Interest on Securities
- No TDS if aggregate interest in the F.Y. is up to ₹10,000.
- No TDS for payments to LIC, GIC, or insurers; 7-Year NSC (IV-Issue); Sec 54EC bonds of Power Finance or Indian Railway Finance; or to a business trust by an SPV.
- Government securities are exempt except taxable 8%, 7.75%, or floating-rate bonds where interest exceeds ₹10,000.
Dividend
- TDS is deducted only at the time of payment.
- No TDS if paid to an individual by non-cash mode up to ₹10,000.
- No TDS if paid to LIC/GIC having beneficial interest, by an SPV to a business trust, or by an IFSC aircraft-leasing unit to another identical IFSC unit.
- Applies to deemed dividend u/s 2(22)(a) to (f).
> ₹50,000 (others than Senior citizen from bank/co op bank/post office)
> ₹10,000 (other cases)
Interest other than Securities
> ₹50,000 (others than Senior citizen from bank/co op bank/post office)
> ₹10,000 (other cases)
- No TDS on savings bank interest, firm-to-partner interest, income-tax refund interest, zero coupon bonds, or payments to banks, LIC, UTI, and specified corporations. NBFCs are not exempt.
- Time deposits are exempt up to ₹50,000, or ₹1,00,000 for senior citizens; other cases are exempt up to ₹10,000.
- Co-operative society payments to members/other societies are exempt unless prior year turnover exceeds ₹50 crores and interest exceeds ₹50,000, or ₹1,00,000 for seniors.
- Interest on deposits with a primary agricultural credit society or a primary credit society or a co-operative land mortgage bank or a co-operative land development bank
- MACT compensation interest is exempt up to ₹50,000. Mahila Samman Savings Certificate interest is exempt.
- For CBS software, TDS is triggered on actual credit to the depositor, not macro provision accounts; thresholds are checked bank-wise.
- For deceased depositors, minor-child interest is reported against the child's PAN. In CGAS accounts, pre-death interest uses the depositor's PAN and post-death interest uses the legal heir's PAN.
- Disputed court deposits do not attract TDS until ownership is decided.
Winnings from lottery, crossword puzzles, card games
- TDS is deducted only at the time of payment.
- No TDS if the single-transaction winning is up to ₹10,000.
- If the prize is in kind, or cash is insufficient, the payer must ensure tax is paid to the Government before releasing the prize.
Winnings from horse race
- TDS is deducted only at the time of payment.
- No TDS if the single-transaction winning is up to ₹10,000.
- Bookmakers deduct tax at 30% on winnings before set-off of losses.
- If the prize is in kind, or cash is insufficient, the payer must ensure tax is paid to the Government before releasing the prize.
Winnings from Online Games
- TDS is deducted at withdrawal and at the end of the F.Y.
- Net Winning = (A+D) - (B+C+E), where A = withdrawals, D = closing balance, B = non-taxable deposits, C = opening balance, and E = previously taxed winnings.
- Multiple accounts of one user are aggregated. Transfers between user accounts are not deposits or withdrawals. Borrowed money deposited is a non-taxable deposit.
- Prizes in kind are treated as equivalent monetary deposit and simultaneous withdrawal; the prize is withheld until tax payment is ensured.
- Bonuses are ignored unless recharacterized and allowed to be withdrawn.
- No TDS for net winnings below ₹100 per month if the shortfall is deducted later or at year-end and the deductor assumes liability if the account balance is insufficient.
Contracts & sub-contracts
- No TDS if a single contract is up to ₹30,000 or aggregate contracts in the P.Y. are up to ₹1,00,000. No TDS for personal-purpose contracts of Ind/HUF.
- "Work" includes advertising, broadcasting, carriage except railways, catering, and job work with client materials; it excludes manufacturing with open-market materials and payments covered by 194J.
- Transporters are exempt if they own 10 or fewer vehicles and furnish PAN.
- For job work, TDS applies only on processing value if material cost is separately shown; otherwise on total value.
- Client to ad agency is covered by 194C; ad agency to TV channel as principal-to-principal is not.
- Cold storage and airport landing/parking charges are covered by 194C. Broadcaster copyright acquisition is 194C, but mere telecast-right acquisition is not.
- Gas sale with transport included is not subject to TDS; transport by a third party is covered by 194C.
Insurance Commission
- No TDS if commission is up to ₹20,000 in the F.Y.
- Common commission/brokerage exclusions include BSNL/MTNL payments to PCO franchises and security underwriting/brokerage.
- Stamp-vendor discount and telecom distributor margin on prepaid kits are treated as principal-to-principal and do not attract TDS.
- Prasar Bharati retained amounts and airline primary/supplementary commissions are treated as commission and attract TDS.
Maturity of Life Insurance Policy
- TDS is deducted at the time of payment.
- No TDS if the payment is below ₹1,00,000 or exempt u/s 10(10D).
- TDS applies only on the income component, meaning maturity amount minus premium.
Payment to NR Sports person / Association / Entertainer
- Covers income of a non-resident non-citizen sportsperson from participation, advertisements, and article contributions.
- Covers guarantee income of non-resident sports associations and performance income of non-resident entertainers.
Commission on sale of lottery tickets
- No TDS if commission is up to ₹20,000 in the F.Y.
- Common commission/brokerage exclusions include BSNL/MTNL payments to PCO franchises and security underwriting/brokerage.
- Stamp-vendor discount and telecom distributor margin on prepaid kits are treated as principal-to-principal and do not attract TDS.
- Prasar Bharati retained amounts and airline primary/supplementary commissions are treated as commission and attract TDS.
Commission and Brokerage
- No TDS if commission/brokerage is up to ₹20,000 in the F.Y.
- No TDS on BSNL/MTNL payments to PCO franchises or on security underwriting/brokerage.
- Stamp-vendor discount and telecom distributor margin on prepaid kits are treated as principal-to-principal and do not attract TDS.
- Prasar Bharati retained amounts and airline primary/supplementary commissions are treated as commission and attract TDS.
Rent
- No TDS if rent is up to ₹50,000 per month.
- Rent includes non-refundable deposits, arrears, advance rent, and warehousing charges; the payee need not be the owner.
- Refundable deposits, lumpsum lease premium/upfront charges for long-term rights, passenger service fees, and IFSC aircraft/ship leases are excluded.
- Mobile towers are treated as plant and machinery and attract 2% TDS.
- Dumper hiring is treated as sub-contract u/s 194C, not rent u/s 194-I.
- Co-owner thresholds are checked individually.
Transfer of Immovable property (except rural agricultural land)
- Applies if consideration or stamp duty value is ₹50,00,000 or more.
- Consideration is aggregated across all transferees and all transferors.
- Consideration includes club membership fees, car parking, electricity, maintenance, and advance fees.
- Form 26QD is required.
Rent of Immovable property by certain individuals
- No TDS if rent is up to ₹50,000 per month.
- TDS is deducted at credit or payment of the last month of the year or tenancy.
- If PAN is not furnished, TDS is 20%, capped at the amount of the last month's rent.
- Form 26QC is required.
Consideration under Joint Development Agreement (JDA)
- Applies only to cash or money consideration under a joint development agreement covered by u/s 45(5A).
Fees for Professional/Technical Services, Royalty, Directors Remuneration
- The ₹50,000 annual limit applies separately for professional services, technical services, royalty, and non-compete fees. No limit applies for director fees.
- Ind/HUF personal-purpose professional services are exempt.
- Ind/HUF crossing turnover limits deduct only for professional or technical services, not royalty or non-compete fees.
- Sports personnel such as umpires, commentators, and anchors fall under professional services.
- Software is royalty; subsequent transfers without modification are exempt if TDS was already deducted u/s 194J or 195.
- TPA hospital settlement payments are covered by 194J.
- Stock exchange BOLT charges are a facility, not technical services, and do not attract TDS.
Income from UTI or Mutual Fund Units
- No TDS if payment is up to ₹10,000 in a P.Y.
- No separate supplementary rule was provided in the additional-information extract for this section.
Compensation on compulsory acquisition of Immovable Property
- TDS is deducted at the time of payment.
- No TDS if compensation is up to ₹5,00,000.
- Does not apply to urban or rural agricultural land.
Payments to Contractors, Commission, Brokerage, FPS
- No TDS if aggregate payment is up to ₹50,00,000.
- Covers personal contracts and Ind/HUF payers not covered by 194C, 194H, or 194J turnover criteria.
- Payer is not required to obtain TAN; tax is deposited online through Form 26QA,26QB,26QC,26QD.
Cash withdrawal from Bank, Co-op. Bank, Post Office
- TDS is deducted at the time of payment.
- Threshold is withdrawal exceeding ₹1 crore, or ₹3 crore for a co-operative society.
- For non-filers of the past 3 years, TDS is 2% over ₹20 lakhs and 5% over ₹1 crore.
- Exemptions include withdrawals by Government , banks & Correspondent, post offices & Correspondent, white-label ATM operators, CRAs, APMC commission agents, and FFMCs.
E-Commerce transactions (Sale of Goods/Service)
- Ind/HUF e-commerce participants are exempt up to ₹5 lakhs if PAN/Aadhaar is furnished.
- Direct payments to the seller are deemed to be through the e-commerce operator.
- Overrides other TDS sections unless the payment is for non-sale services such as advertisements. Covers goods as well as professional/technical services.
- Payment gateways need not deduct if the operator has already deducted.
- Insurance aggregator deducts in the first year; insurance company deducts on commission in later years.
- E-auction platforms are exempt if they only provide price discovery and payment happens outside the portal.
- For ONDC multiple operators, seller-side ECO complies if making final payment; buyer-side ECO complies if seller-side ECO is the actual seller.
- Convenience, logistics, and delivery fees are included. Seller discount reduces gross amount; ECO discount does not.
TDS on Senior Citizen Pension
- Applies when the resident individual is 75 or older, receives pension and interest from the same specified bank, and submits Form 12BBA.
- The bank computes total income after Chapter VI-A deductions and 87A rebate, then applies slab rates.
- The assessee is exempt from filing ROI once the specified bank deducts tax under this mechanism.
Purchase of Goods
- Applies on the sum exceeding ₹50 lakhs. Rate is 5% if PAN is not furnished.
- First year of business incorporation is exempt because there is no prior-year turnover. Non-business turnover is excluded for turnover checks.
- Subordinate to other TDS provisions and TCS u/s 206C(1), 206C(1F), and 206C(1G), but takes priority over Sec 194-O.
- Exemptions include recognised stock, commodity, and power exchanges; non-resident buyer without PE; seller whose entire income is exempt; and Government departments selling goods. PSUs/Authorities are covered.
- Indirect taxes are excluded if separately invoiced, but included for advance payments.
- Purchase returns are adjusted against future purchases.
Any benefit or perquisite from business/profession
- No TDS if benefits/perquisites are up to ₹20,000 in the F.Y. If the benefit is in kind, the provider must ensure tax is paid.
- Applies regardless of whether the recipient is taxable. Covers capital assets, free samples, incentives, trips, and event tickets.
- Excludes sales discounts, cash discounts, rebates, bonus shares, right shares, pure-agent reimbursements, loan waivers by banks/NBFCs, and embassies.
- Conferences are exempt if for product launch, discussion, training, or account reconciliation. Leisure, family members, or overstay are taxable, except one day before/after.
- Out-of-pocket reimbursements are covered unless invoiced directly to the client or TDS was already deducted on total gross consideration.
- For group activities, the provider can opt to disallow the expense instead of tracking TDS for each participant.
- Value benefits at purchase price, manufacturing price, or FMV excluding GST. If a business asset is received, depreciation can be claimed on FMV.
Transfer of Virtual Digital Asset (VDA)
- No specific additional rule was provided in the supplementary extract for this section.
- Apply the general rules in the main row, including deduction at credit or payment, whichever is earlier.
Salary, remuneration, commission, bonus or interest to a partner
- Limit applies per payee.
- Covers salary, remuneration, commission, bonus, or interest paid by a firm, including LLP, to a partner.
- Partner salary is not covered u/s 192; from April 1, 2025, this section applies if the payment exceeds ₹20,000.
| S.No | Section | Nature of Payment | Threshold Limit | Payer | Payee | TDS Rate | Timing of Deduction | Statutory Notes & Edge Cases |
|---|---|---|---|---|---|---|---|---|
| 1 | Sec 192 | Salary Salary & PF |
Basic exemption limit / Tax based on Slab Rate | Any Person / Employer | Employee (Resident/NR) | Average rate of income-tax / Slab Rate | At the time of payment |
|
| 2 | Sec 192A | Accumulated balance/Premature withdrawal of PF Salary & PF |
≥ ₹50,000 | EPF Scheme Trustees / Any Person | Employee (Resident/NR) | 10% | At the time of payment |
|
| 3 | Sec 193 | Interest on Securities Securities & Dividend |
> ₹10,000 in a F.Y. | Any Person | Resident Person | 10% | At the time of credit or payment, whichever is earlier |
|
| 4 | Sec 194 | Dividend Securities & Dividend |
> ₹10,000 in a F.Y. | Domestic Company / Principal Officer | Resident Person | 10% | Before making payment / at the time of payment |
|
| 5 | Sec 194A | Interest other than Securities Securities & Dividend |
> ₹1,00,000 (Senior citizen from bank/co op bank/post office) > ₹50,000 (others than Senior citizen from bank/co op bank/post office) > ₹10,000 (other cases) |
Any Person (excluding Ind/HUF unless prior year T/O > ₹1 Cr or G/R > ₹50 Lakhs) | Resident Person | 10% | At the time of credit or payment, whichever is earlier |
|
| 6 | Sec 194B | Winnings from lottery, crossword puzzles, card games Winnings & Online Gaming |
> ₹10,000 in a F.Y. (single transaction) | Any Person | Any Person | 30% | At the time of payment |
|
| 7 | Sec 194BB | Winnings from horse race Winnings & Online Gaming |
> ₹10,000 in single transaction | Any Person (Bookmaker / Licensee) | Any Person | 30% | At the time of payment |
|
| 8 | Sec 194BA | Winnings from Online Games Winnings & Online Gaming |
On net winnings (No threshold, but concession if withdrawal ≤ ₹100 in a month under conditions) | Any Person | Any Person | 30% | At withdrawal and at the end of the F.Y. |
|
| 9 | Sec 194C | Contracts & sub-contracts Contracts & Professional |
> ₹30,000 (single) or > ₹1,00,000 (aggregate in a F.Y.) | Specified entities / Any Person (Ind/HUF requires prior year T/O > ₹1 Cr or G/R > ₹50 Lakhs) | Resident Person | 1% for Ind/HUF, 2% for others | At credit or payment, whichever is earlier |
|
| 10 | Sec 194D | Insurance Commission Contracts & Professional |
> ₹20,000 in a F.Y. | Any Person | Resident Person | 2% (10% if payee is a domestic company) | At credit or payment, whichever is earlier |
|
| 11 | Sec 194DA | Maturity of Life Insurance Policy Contracts & Professional |
≥ ₹1,00,000 in a F.Y. | Any Person | Resident Person | 2% on the income component | At the time of payment |
|
| 12 | Sec 194E | Payment to NR Sports person / Association / Entertainer Contracts & Professional |
None mentioned | Any Person | NR Sports person, Association, or Entertainer | 20.8% (20% + 4% HEC) | At the time of payment |
|
| 13 | Sec 194G | Commission on sale of lottery tickets Contracts & Professional |
> ₹20,000 in a F.Y. | Any Person | Any Person | 2% | At credit or payment, whichever is earlier |
|
| 14 | Sec 194H | Commission and Brokerage Contracts & Professional |
> ₹20,000 in a F.Y. | Any Person (excluding Ind/HUF unless prior year T/O limits apply) | Resident Person | 2% | At credit or payment, whichever is earlier |
|
| 15 | Sec 194-I | Rent Rent & Immovable Property |
> ₹50,000 to a person per month or part of the month | Any Person (excluding Ind/HUF unless prior year T/O limits apply) | Resident Person | 2% for Plant/Machinery/Equipment; 10% for Land/Building/Furniture | At credit or payment, whichever is earlier |
|
| 16 | Sec 194-IA | Transfer of Immovable property (except rural agricultural land) Rent & Immovable Property |
≥ ₹50,00,000 (Consideration or SDV) | Any Person / Transferee (Buyer) | Resident Person / Transferor (Seller) | 1% of consideration or SDV, whichever is higher | At credit or payment, whichever is earlier |
|
| 17 | Sec 194-IB | Rent of Immovable property by certain individuals Rent & Immovable Property |
> ₹50,000 per month or part of a month | Individual / HUF (not covered u/s 194-I) | Resident Person | 2% | In the last month of the P.Y. or tenancy |
|
| 18 | Sec 194-IC | Consideration under Joint Development Agreement (JDA) Rent & Immovable Property |
No specified threshold | Any Person | Resident Person | 10% | At credit or payment, whichever is earlier |
|
| 19 | Sec 194J | Fees for Professional/Technical Services, Royalty, Directors
Remuneration Contracts & Professional |
> ₹50,000 in a F.Y. for each category (No limit for Director's fees) | Any Person (excluding Ind/HUF unless prior year T/O limits apply) | Resident Person | 2% for call center, technical services, or certain film royalties; 10% in other cases | At credit or payment, whichever is earlier |
|
| 20 | Sec 194K | Income from UTI or Mutual Fund Units Securities & Dividend |
> ₹10,000 in a F.Y. | Any Person / MF Administrator | Resident Person | 10% | At credit or payment, whichever is earlier |
|
| 21 | Sec 194LA | Compensation on compulsory acquisition of Immovable Property Rent & Immovable Property |
> ₹5,00,000 in a F.Y. | Any Person | Resident Person | 10% | At the time of payment |
|
| 22 | Sec 194M | Payments to Contractors, Commission, Brokerage, FPS Contracts & Professional |
> ₹50,00,000 in a F.Y. | Individual/HUF (not liable to deduct TDS u/s 194C, 194H, 194J) | Resident Person | 2% | At credit or payment, whichever is earlier |
|
| 23 | Sec 194N | Cash withdrawal from Bank, Co-op. Bank, Post Office Cash & E-Commerce |
> ₹1 Crore in a P.Y. (> ₹3 Crore if payee is a co-op society; > ₹20 Lakhs if non-filer) | Bank, Co-op. Bank, or Post Office | Any Person | 2% (5% if withdrawal > ₹1 Crore and payee is a non-filer for 3 preceding P.Y.s) | At the time of payment |
|
| 24 | Sec 194-O | E-Commerce transactions (Sale of Goods/Service) Cash & E-Commerce |
> ₹5 Lakhs in a F.Y. for Individual/HUF participants | E-Commerce Operator | E-Commerce Participant (Resident) | 0.1% on gross amount (5% if PAN not furnished) | At credit or payment, whichever is earlier |
|
| 25 | Sec 194P | TDS on Senior Citizen Pension Cash & E-Commerce |
Basic exemption limit | Specified Bank | Resident Individual (age 75+) | Slab Rate / Rates in force | N/A (Bank computes tax liability) |
|
| 26 | Sec 194Q | Purchase of Goods Goods, Perks & VDAs |
> ₹50 Lakhs in a P.Y. | Any Person (Buyer) with prior P.Y. business T/O > ₹10 Crores | Resident Person (Seller) | 0.1% of sum exceeding ₹50 Lakhs | At credit or payment, whichever is earlier |
|
| 27 | Sec 194R | Any benefit or perquisite from business/profession Goods, Perks & VDAs |
> ₹20,000 in a F.Y. | Any Person (excluding Ind/HUF unless prior year T/O limits apply) | Resident Person | 10% | Before providing the benefit/perquisite |
|
| 28 | Sec 194S | Transfer of Virtual Digital Asset (VDA) Goods, Perks & VDAs |
≤ ₹50,000 for specified person / > ₹10,000 for others in a F.Y. | Any Person | Resident Person | 1% | At credit or payment, whichever is earlier |
|
| 29 | Sec 194T | Salary, remuneration, commission, bonus or interest to a partner Partner Remuneration |
> ₹20,000 during the F.Y. | Firm (Including LLP) | Partner | 10% | At credit or payment, whichever is earlier |
|
🛡️ Tax Collected at Source (TCS) Provisions u/s 206C
Comprehensive coverage of high-yield TCS provisions applicable for AY 2025-26 under Section 206C(1F) and Section 206C(1G).
- Scope & Threshold: Applies to retail sale of motor vehicles exceeding ₹10 Lakhs. Does not apply on manufacturer-to-dealer commercial sales.
- Per-Transaction Test: The ₹10 Lakh threshold is evaluated per individual vehicle/purchase, not in aggregate across the financial year.
- Notified Luxury Goods: Covers wrist watches, high-value art pieces, collectibles, yachts, helicopters, sunglasses, designer bags, luxury shoes, sports kits, home theatres, and polo/race horses exceeding ₹10 Lakhs.
- Exempt Buyers: Public sector companies carrying passengers/goods, Central/State Governments, Foreign Embassies, High Commissions, and Local Authorities.
- Timing of Collection: At the time of receipt of sale consideration by any mode.
- LRS Threshold: TCS applies on remittances under the Liberalised Remittance Scheme (LRS) exceeding ₹10 Lakhs (combined aggregate threshold for all purposes in a F.Y.).
- Education Loan u/s 80E: Remittances funded through financial institution loans under Section 80E attract a concessional TCS rate of 0.5% above ₹10 Lakhs.
- Medical & Self-Funded Education: 5% TCS on amount exceeding ₹10 Lakhs.
- Other LRS Remittances: 20% TCS on amount exceeding ₹10 Lakhs.
- Overseas Tour Program Packages (OTPP):
- 5% TCS on package cost up to ₹10 Lakhs (No basic exemption).
- 20% TCS on the amount exceeding ₹10 Lakhs.
- Requires multi-element package (hotel + travel); standalone flight or standalone hotel bookings are excluded.
- Credit Cards Abroad: Expenses via international credit cards while travelling abroad are currently excluded from LRS and attract no TCS.
⚖️ Non-Residents (Sec 195) & Landmark Judicial Rulings
Essential statutory overrides, double taxation relief precedents, and deductor liabilities established by the Supreme Court of India and High Courts.
- Universal Applicability: Applies to all payers, whether resident or non-resident, regardless of whether they have a Permanent Establishment (PE) or business connection in India.
- Chargeability Test: TDS is deductible only on sums chargeable to income tax under the Act. Payer can apply u/s 195(2) or 195(3) for nil/lower deduction certificates.
- Demurrage Exemption: Demurrage charges paid to non-resident shipping companies covered by Section 172 are exempt from TDS u/s 195.
- Overseas Selling Agents: Commission paid to foreign agents operating strictly outside India without any Indian business operations is not taxable in India and requires no TDS.
- DTAA vs Sec 206AA (Supreme Court - Air India Ltd): The beneficial tax rate under Double Tax Avoidance Agreements (DTAA) overrides the punitive 20% higher TDS rate under Section 206AA, even if the non-resident payee does not possess an Indian PAN.
- Deductee Protection (Delhi HC - BDR Finvest): Once tax has been deducted at source by the payer, the deductee cannot be denied TDS credit merely because the deductor failed to deposit the tax into the Government Treasury. Recovery must proceed against the deductor.
- Restaurant Tips (Supreme Court - ITC Ltd): Tips collected from customers and disbursed to banquet and restaurant waitstaff do not constitute salary; employer is not liable to deduct TDS u/s 192.
- Sec 196 Universal Exemption: No TDS on payments made to the Central/State Government, Reserve Bank of India (RBI), Statutory Corporations, or SEBI-registered Mutual Funds.
- Separately Invoiced GST: As per CBDT Circulars, TDS on payments for services is deducted strictly on the value of service excluding GST, provided GST is separately indicated on the invoice.
⏱️ Interest Computation under Section 201(1A)
Strict liability interest framework for late deduction and late deposit of TDS. Non-discretionary, mandatory, and automatic.
Interest under Section 201(1A) is automatic, compensatory, and mandatory. It cannot be waived on grounds of bona fide dispute, absence of willful default, or administrative delay.