MAHINDRA & MAHINDRA LIMITED 5 Finance Act, 2026 and amendments thereof. Shareholders are requested to update their Permanent Account Number (PAN) with the Company/KFintech (in case of shares held in physical mode) and Depositories (in case of shares held in demat mode). For Resident Shareholders: Tax shall be deducted at source under section 393(1) [Table Sl. No. 7] of the IT Act at the rate of 10% on the amount of Dividend declared and paid by the Company during the Financial Year (“FY“) 2026-27 provided a valid PAN is provided by the shareholder. In case shareholders do not have PAN or have invalid PAN or have not registered their valid PAN details with their DP/ KFintech or shareholder's PAN is not linked with Aadhaar, TDS at the rate of 20% shall be deducted under section 397(2) of the IT Act. a) For Resident Individual: No TDS shall be deducted on the Dividend payable to a resident Individual if the total dividend to be received during FY 2026-27 does not exceed Rs. 10,000 as per section 393(4) [Table SI. No.10]. Please note that this includes the future dividends, if any, which may be declared by the Board in the FY 2026-27. Separately, in cases where the shareholder provides Form 121 (applicable to resident individuals/ including individuals above the age of 60 years), no tax at source shall be deducted provided that the eligibility conditions are being met. It is implicit that, PAN is mandatory. Members are requested to note that in case their PAN is not registered, the tax will be deducted at a higher rate of 20%. b) For Resident Non-Individual: No tax shall be deducted on the dividend payable to the following resident non-individuals where they provide relevant details and documents as per format of Declaration regarding Category and Beneficial Ownership of shares: i. Insurance Companies: Self-declaration that it qualifies as 'Insurer' as per section 2(7A) of the Insurance Act, 1938 and has full beneficial interest with respect to the ordinary shares owned by it along with self-attested copy of PAN card and certificate of registration with Insurance Regulatory and Development Authority of India (IRDAI)/LIC/GIC. ii. Mutual Funds: Self-declaration that it is registered with SEBI and is notified under Schedule VII [Table: SI. No. 20 or 21] of the IT Act along with self-attested copy of PAN card and certificate of registration with SEBI. iii. Alternative Investment Fund (AIF): Self declaration that its income is exempt under Schedule V [Table SI. No. 1] of the Act and they are registered with SEBI as Category I or Category II AIF along with self-attested copy of the PAN card and certificate of AIF registration with SEBI. iv. New Pension System (NPS) Trust: Self declaration that it qualifies as NPS trust and income is eligible for exemption under Schedule VII [Table SI. No. 41] of the IT Act and is being regulated by the provisions of the Indian Trusts Act, 1882 along with self-attested copy of the PAN card. v. Recognized Provident Fund: Self-attested copy of a valid order from Commissioner under Rule 3 of Part A of Eleventh Schedule to the IT Act or self-attested valid documentary evidence (e.g. relevant copy of registration, notification, order, etc.) in support of the provident fund being established under a scheme framed under the Employees' Provident Funds Act, 1952. vi. Approved Superannuation Fund: Self-attested copy of valid approval granted by Commissioner under Rule 2 of Part B of Eleventh Schedule to the IT Act. vii. Approved Gratuity Fund: Self-attested copy of valid approval granted by Commissioner under Rule 2 of Part B of Eleventh Schedule to the IT Act. viii. National Pension Scheme: A declaration that the NPS is exempt under section 393(9) of the IT Act and registration taken under Pension Fund Regulatory and Development Authority Act, 2013. ix. Other non-individual shareholders: Selfattested copy of documentary evidence supporting the exemption along with self-attested copy of PAN card. x. In case a shareholder is Government (Central/ State), no TDS is required to be deducted as per section 393 of the IT Act. In case shareholders (both individuals and non-individuals) provide certificate under section 197 / 395(1) of the Income-tax Act, 1961 / Income Tax Act, 2025 for lower/Nil withholding of taxes, rate specified in the said certificate shall be considered on submission of selfattested copy to the Company. For Non-resident Shareholders: Taxes are required to be withheld in accordance with the provisions of section 393(2) [Table SI. No. 17] read with section 207 of the IT Act at the rate of 20% (plus applicable surcharge and cess) on the amount of Dividend payable to them. In case of GDRs and Foreign Portfolio Investors (“FPI”)/ Foreign Institutional Investors (“FII”), the withholding tax shall be as per the rates specified in sections 393(2) [Table SI. No. 15] of the IT Act respectively (plus applicable surcharge and cess) on the amount of Dividend payable to them. For non-resident shareholders who are tax residents of Notified Jurisdictional Area as defined under section 176 of the IT Act, tax will be required to be deducted at the rate 30%. For Sovereign Wealth Fund, Pension Funds, Other bodies notified under Schedule V (7) of the IT Act, self-declaration is required to be provided substantiating fulfilment of conditions prescribed under the aforesaid section of the IT Act. In case non-resident shareholders provide a certificate issued under section 395(1) of the Income-tax Act, 1961/ Incometax Act, 2025 for lower/Nil withholding of taxes, rate specified in the said certificate shall be considered on submission of self-attested copy of the same. However, as per section 159 of the IT Act, the non-resident shareholder has the option to be governed by the provisions of the Double Tax Avoidance Agreement (“DTAA”) between India and the country of tax residence of the shareholder, if they are more beneficial to them. For this purpose, i.e. to avail the Tax Treaty benefits, the non-resident shareholder will have to provide the following:
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