Rule 159: Transactions requiring PAN quotation or a PAN application
Rule 159 connects sixteen transaction categories to PAN quotation, specified value tests and the person receiving or issuing the transaction document. It also distinguishes limited Form 97 alternatives from cases requiring a PAN application, with separate minor, government, non-resident and IFSC provisions.
Official notified Income-tax Rules, 2026Need advice on Rule 159?
This article is for general information. Read the official Rules and applicable Act amendments, including the Taxation and Other Laws (Amendment) Act, 2026. If you need professional advice for your situation, contact Bizeneed.
On this page
- Bare law
- Start with the actual transaction row
- Key business value tests are different
- A declaration is not a universal replacement for PAN
- Some transactions require a PAN application
- Check the exact exceptions
- Recipients must verify and link the information
- Keep quotation, authentication and reporting duties distinct
- Key takeaways
- Practical checklist
- FAQs
- Glossary
- Official sources
Bare law
Rule 159 - Transactions in relation to which Permanent Account Number is to be quoted or applied for purposes of section 262(1)(f) and 262(10)(c) and (e)
(1) Every person shall quote his Permanent Account Number in all documents, pertaining to the transactions specified in column 2 for value of transaction specified in column 3 of the following Table : —
Sl.no. Nature of transaction Value of transaction Person receiving or issuing the document in relation to transaction in column (2) 1. Making an application to any banking company or a co-operative bank to which the Banking Regulation Act, 1949 (10 of 1949), applies (including any bank or banking institution referred to in section 51 of that Act) or to any other company or institution, for issue of a credit card. All such transactions. (i)Manager or officer of a banking company or co-operative bank; or (ii)the principal officer of the company; or (iii)the principal officer of the institution, as the case may be. 2. Opening of an account with a depository, participant, custodian of securities or any other person registered under section 12(1A) of the Securities and Exchange Board of India Act, 1992 (15 of 1992). All such transactions. The depository, participant, custodian of securities or any other person registered under section 12(1A) of the Securities and Exchange Board of India Act, 1992 (15 of 1992). 3. Payment to the Reserve Bank of India, constituted under section 3 of the Reserve Bank of India Act, 1934 (2 of 1934) for acquiring bonds issued by it. Amount exceeding ₹ 50000. The officer of the Reserve Bank of India, constituted under section 3 of the Reserve Bank of India Act, 1934 (2 of 1934), or of any agency bank authorised by the Reserve Bank of India. 4. Payment to a Mutual Fund for purchase of its units. Amount exceeding ₹ 50000. The trustee or any other person duly authorised by the trustee of a Mutual Fund. 5. A contract for sale or purchase of securities (other than shares) as defined in section 2(h) of the Securities Contracts (Regulation) Act, 1956 (42 of 1956). Amount exceeding ₹ 100000 per transaction. (i) The principal officer of the company; or (ii) stock-broker, sub-broker, share transfer agent, banker to an issue, trustee of a trust deed, registrar to issue, merchant banker, underwriter, portfolio manager, investment adviser and such other intermediaries registered under section 12(1) of the Securities and Exchange Board of India Act, 1992 (15 of 1992), as the case may be. 6. Deposit with — (i) a banking company or a co-operative bank to which the Banking Regulation Act, 1949 (10 of 1949), applies (including any bank or banking institution referred to in section 51 of that Act); or (ii) post office. Cash deposits aggregating to ten lakh rupees or more in a financial year, in one or more account of a person (i) Manager or officer of a banking company or co-operative bank; or (ii) postmaster; or (iii) the principal officer of the institution, as the case may be. 7. Withdrawal with — (i) a banking company or a co-operative bank to which the Banking Regulation Act, 1949 (10 of 1949), applies (including any bank or banking institution referred to in section 51 of that Act); or (ii) post office. Cash withdrawals aggregating to ten lakh rupees or more in a financial year, in one or more account of a person (i) Manager or officer of a banking company or co-operative bank; or (ii) postmaster; or (iii) the principal officer of the institution, as the case may be. 8. Sale or purchase of — (i) motor vehicle or vehicle, as defined in section 2(28) of the Motor Vehicles Act 1988 (59 of 1988), which requires registration by a registering authority under Chapter IV of that Act, except ‗tractor‘ as defined in section 2(44) of the said Act; or (ii) motor cycle as defined in section 2(27) of the Motor Vehicles Act 1988 (59 of 1988). Amount exceeding ₹ 500000. The person who sells the motor vehicle or motor cycle. 9. Sale or purchase, by any person, of shares of a company not listed in recognised stock exchange. Amount exceeding ₹ 100000 per transaction The principal officer of a company issuing such shares 10. Payment to a company or an institution for acquiring debentures or bonds issued by it. Amount exceeding ₹ 50000 The principal officer of a company or an institution issuing such bonds or debentures. 11. Purchase or sale or gift or joint development agreement by any person of any immovable property. Amount exceeding twenty lakh rupees or valued by stamp valuation authority referred to in section 78, at an amount exceeding twenty lakh rupees. Inspector-General appointed under section 3 of the Registration Act, 1908 (16 of 1908) or Registrar or Sub-Registrar appointed under section 6 of that Act. 12. Opening an account other than a time-deposit referred in Sl. No. 13 and a Basic Savings Bank Deposit Account with (i) a banking company; or (ii) a co-operative bank to which the Banking Regulation Act, 1949 (10 of 1949), applies (including any bank or banking institution referred to in section 51 of that Act). All such transactions. (i) Manager or officer of a banking company or co-operative bank; or (ii) the principal officer of the institution, as the case may be. 13. A time deposit with — (i) a banking company or a co-operative bank to which the Banking Regulation Act, 1949 (10 of 1949), applies (including any bank or banking institution referred to in section 51 of that Act); or (ii) a post office; or (iii) a Nidhi referred to in section 406 of the Companies Act, 2013 (18 of 2013); or (iv) a non-banking financial company which holds a certificate of registration under section 45-IA of the Reserve Bank of India Act, 1934 (2 of 1934), to hold or accept deposit from public. Amount exceeding ₹ 50000 or aggregating to more than ₹ 500000 during a financial year. (i) Manager or officer of a banking company or co-operative bank; or (ii) postmaster; or (iii) the principal officer of the company; or (iv) the principal officer of the institution, as the case may be. 14. Commencement of account-based relationship with an insurer as defined in section 2(9) of the Insurance Act, 1938 (4 of 1938) All such transactions where insurance premium exceeds ₹ 50000 during a financial year. The manager or officer of an insurer. 15. Payment to (i) a hotel or restaurant; or (ii) a convention Centre; or (iii) a banquet hall; or (iv) any person engaged in event management, against a bill or bills at any one time. Payment in cash of an amount exceeding ₹ 100000. The person issuing the document including the bill. 16. Sale or purchase by any person, of goods or services of any nature other than those specified at Sl. Nos. 1 to 15, if any. Amount exceeding ₹ 200000 per transaction. The person issuing the document including the bill. (2) In respect of transactions mentioned in column (2) of the Table in sub-rule (1) — (a) any person who is a minor, not having any income chargeable to tax, and who enters into any of the said transactions, shall quote the Permanent Account Number of his father or mother or guardian, as the case may be, in the document pertaining to the said transaction; (b) any person, not being a company or a firm, and who does not have a Permanent Account Number, entering into any of the transactions mentioned at Sl. Nos. 11 to 16, shall make a declaration in Form No. 97 giving therein the particulars of such transaction; (c) out of the transactions mentioned in clause (ii), a foreign company entering into transactions at Sl. No. 12 or 13 in an IFSC banking unit, who does not have — (I) a Permanent Account Number; and (II) any income chargeable to tax in India, shall make a declaration in Form No. 97.
(3) For the purposes of section 262(1)(f), any person, not being a company or a firm, and who does not have Permanent Account Number, entering into— (a) any of the transactions mentioned at Sl. No. 1 to 10; (b) transaction mentioned at Sl. No. 11, where amount of immovable property exceeds forty-five lakh rupees or more, or its value as per stamp valuation authority referred to in section 78 of the Registration Act, 1908 (16 of 1908) exceeds forty-five lakh rupees, shall apply for Permanent Account Number.
(4) The provisions of sub-rule (3) shall not apply in a case, — (a) where the person carrying out transactions as per Sl. Nos. 1 to 10 of column (2) of the Table in sub-rule (1), is a non-resident (not being a company) or a foreign company; (b) the transaction is entered into with an IFSC banking unit; and (c) such non-resident (not being a company) or the foreign company does not have any income chargeable to tax in India.
(5) The person referred to in column (4) of Table in sub-rule (1), who has received or issued any document, shall ensure that— (a) Permanent Account Number after verification, has been duly and correctly mentioned therein or as the case may be, a declaration in Form No. 97 has been duly furnished with complete particulars; (b) the valid Permanent Account Number or the fact of furnishing of Form No. 97, is duly mentioned in the records maintained for the transactions referred to in column (2) of Table in sub-rule (1); and (c) the Permanent Account Number or the details of Form No. 97 are linked and mentioned in any information furnished to the income-tax authority or any other authority or agency under any provision of the Act or any rule made thereunder.
(6) The provisions of sub-rule (1) shall not apply to the following class or classes of persons:— (a) the Central Government, State Governments and the consular offices; and (b) the non-residents referred to in section 2(72) in respect of the transactions referred to against Sl. No. 1 or 3 or 15 or 16 of the Table.
(7) For the purposes of this rule,- (a) "IFSC banking unit" means a financial institution defined under section 3(1)(c) of the International Financial Services Centres Authority Act, 2019 (50 of 2019), that is licensed or permitted by the International Financial Services Centres Authority to undertake permissible activities under the International Financial Services Centres Authority (Banking) Regulations, 2020; and (b) "time deposit" means any deposit which is repayable on the expiry of a fixed period.
(8) The Principal Director General of Income-tax (Systems) or Director General of Income-tax (Systems) shall lay down the formats and standards along with procedure as regards the manner of authentication of Permanent Account Number.
Rule breakdown
Start with the actual transaction row
The sixteen rows cover credit cards, securities accounts, investments, cash deposits and withdrawals, vehicles, immovable property, banking relationships, time deposits, insurance, hospitality or event payments, and residual goods or services.
Some rows cover all such transactions; others use an amount, a per-transaction test or a financial-year aggregate. Identify the exact row before choosing a threshold.
Key business value tests are different
The cash-deposit and cash-withdrawal rows use ₹10 lakh or more aggregated during a financial year in one or more accounts. The specified vehicle row uses an amount exceeding ₹5 lakh. The property row includes the stated transaction amount or stamp value exceeding ₹20 lakh.
Time deposits use an amount exceeding ₹50,000 or more than ₹5 lakh aggregated during the financial year. The listed hospitality and event-payment row concerns cash exceeding ₹1 lakh against a bill or bills at one time; the residual goods-or-services row uses more than ₹2 lakh per transaction. Read the full table and exceptions for each case.
A declaration is not a universal replacement for PAN
A person other than a company or firm, without PAN, uses Form 97 for the stated rows 11–16, subject to the rule’s other requirements. A separate IFSC-bank provision addresses the specified foreign-company transactions in rows 12 or 13 where there is no PAN and no Indian taxable income.
Do not offer Form 97 as an unrestricted alternative for every customer or transaction.
Some transactions require a PAN application
Sub-rule (3) requires a person other than a company or firm without PAN to apply when entering the listed rows 1–10, and contains an additional immovable-property trigger referring to ₹45 lakh. Its printed property-value wording and cross-reference should be read carefully with the current parent provision before applying a boundary case.
Rule 158 separately sets the advance-application timing for the prescribed intended transaction. The Form 97 provision should not be used to overlook an applicable PAN-application duty.
Check the exact exceptions
A minor with no taxable income quotes the stated parent’s or guardian’s PAN. The government and consular-office exception and the specified non-resident exception have their own scope; the latter identifies particular table rows.
The IFSC exception to the application requirement has cumulative conditions, including the stated non-resident or foreign-company category, transaction with an IFSC banking unit and no income chargeable in India. Do not generalise it to all overseas customers.
Recipients must verify and link the information
The person in the table’s fourth column must ensure verified PAN quotation or a complete Form 97 where applicable, record the PAN or declaration fact, and link the details in information furnished under the Act or Rules.
This is an operational obligation for the receiving or issuing person, not merely a request that the customer write a number on a form.
Keep quotation, authentication and reporting duties distinct
Rule 159’s table should be read alongside the separate authentication requirements in Rule 161 and declaration reporting in current Rule 160 where applicable. Their thresholds and purposes should not be merged.
Retain the transaction classification, value calculation, PAN verification or declaration and relevant reporting record. Check current official Systems instructions for authentication.
Key takeaways
Sixteen transaction rows
Match nature, value and recipient columns.
Different threshold measures
All-transactions, per-transaction and annual aggregate tests differ.
Form 97 is limited
It does not remove every PAN-application requirement.
Recipient duties continue
Verify, record and link the PAN or declaration details.
Practical checklist
- Classify the transaction and value measure.
- Check whether PAN quotation, application or a declaration is required.
- Apply exceptions only within their stated scope.
- Verify and link PAN or declaration information.
Avoid
- Do not substitute one threshold for every row.
- Do not use Form 97 as a blanket PAN substitute.
- Do not merge the separate quotation and authentication rules.
FAQs
Can every person without PAN submit Form 97 instead?
No. The declaration routes are limited by person and transaction category, and separate PAN-application duties may apply.
Does the ₹10 lakh cash threshold mean Rule 161’s authentication rule has the same threshold?
No. Read each rule separately; the quotation and authentication provisions have their own transaction tables.
Which PAN does a minor without taxable income quote?
Sub-rule (2)(a) specifies the father’s, mother’s or guardian’s PAN, as applicable.
Is the recipient’s duty complete merely by collecting a number?
No. Sub-rule (5) requires verification, correct recording and linkage in the specified information furnished.
Does the property row cover only an ordinary sale?
The table expressly includes purchase, sale, gift and joint development agreement, with its stated value test.
Glossary
- Form 97
- The declaration allowed in the particular no-PAN cases specified by Rule 159.
- Transaction recipient
- The person in the table’s fourth column responsible for the stated verification and recording duties.