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Case lawHigh Court › CIT v. N. Sundarraman (Madras High Court) — deposits funded by convertible foreign exchange routed through NRE accounts later redesignated as NRNR keep the s.115E rate, and a wrong 'resident' description in the return does not alter the assessee's real status
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CIT v. N. Sundarraman (Madras High Court) — deposits funded by convertible foreign exchange routed through NRE accounts later redesignated as NRNR keep the s.115E rate, and a wrong 'resident' description in the return does not alter the assessee's real status

My client remitted his overseas salary into NRE accounts, later had them redesignated as NRNR deposits, and described himself as 'Resident' in his return by mistake while claiming section 115H. The assessing officer says he is a resident, that no valid section 115H declaration was filed with the return, and has denied the twenty per cent rate. Is there anything in this?

My client remitted his overseas salary into NRE accounts, later had them redesignated as NRNR deposits, and described himself as 'Resident' in his return by mistake while claiming section 115H. The assessing officer says he is a resident, that no valid section 115H declaration was filed with the return, and has denied the twenty per cent rate. Is there anything in this?

Yes, on two grounds the Madras High Court accepted. First, on the facts found by the Tribunal the redesignation of the NRE accounts into NRNR accounts had been made only out of the convertible foreign exchange lying to the assessee's credit in accounts opened with the inflow of the original foreign exchange transferred to India as approved by the Reserve Bank of India, so the deposits remained foreign exchange assets. Second, the Court held that the assessee's real status cannot be denied merely because he made a wrong declaration when he satisfied all the conditions, and that being 'not ordinarily resident' he was not a 'resident' and so fell within the definition of non-resident Indian in section 115C(e) and was entitled to section 115E in its own right, with no obligation to file any declaration under section 115H.

Decided by the High Court (D. Murugesan J and P.P.S. Janarthana Raja J (common judgment delivered by D. Murugesan J), High Court of Judicature at Madras) on 2012-02-07, reported as Tax Case (A) Nos. 1053 to 1056 of 2004; appeals under section 260-A against the order dated 29 December 2003 of the Income Tax Appellate Tribunal, Chennai 'A' Bench in I.T.A. Nos. 1379/Mds/2003 to 1382/Mds/2003; assessment years 1994-95 to 1997-98. It bears on section 115C, section 115C(e), section 115E, section 115H, section 6, section 6(6), section 10(15)(iv)(fa), section 64(1)(iv), section 147, section 143(2), section 148, section 260A of the Income Tax Act 1961, in Residence & Treaty Benefit, Reassessment & Reopening, Capital Gains Exemptions and Evidence & Burden of Proof matters.

Still good law. Followed by the same High Court in respect of the same assessee for a later year: CIT v. Shri N. Sundararaman, Tax Case (Appeal) No. 101 of 2008, decided 17 February 2015 by R. Sudhakar and R. Karuppiah JJ for AY 1998-99, read in full this pass at indiankanoon.org/doc/159985668/. There, both counsel fairly submitted that the first substantial question of law — entitlement to the concessional rate under section 115H where the procedural and substantive requirements of Chapter XII-A were said not to be satisfied — had already been decided by the same Court in favour of the assessee in T.C.(A) Nos. 1053 to 1056 of 2004 dated 7 February 2012, and following that decision the Revenue's appeal was dismissed. Caveat on that corroboration: the fetch of the 2015 judgment returned paragraphs 1 to 11 verbatim except paragraph 10, where the reproduction of the 2012 judgment came back as a bracketed editorial placeholder rather than as text, so paragraph 10 of the 2015 judgment has not been read. No decision doubting or dissenting from the 2012 judgment was located, but no systematic later-treatment search was run beyond the indiankanoon queries recorded in NOTES-B84.md, and no Supreme Court consideration was found. Note separately that section 115E as reproduced in this judgment charges long-term capital gains at a flat ten per cent; that rate is superseded by amendment for transfers on or after 23 July 2024, though nothing in the decision turned on it, the income in issue being deposit interest.

Why it matters

This is the decision to reach for when the officer attacks the FUNDING CHAIN rather than the original remittance. Money that comes in as convertible foreign exchange rarely stays in the account it arrived in: it is renewed, redesignated, moved between NRE, NRNR and FCNR products. The Court accepted the Tribunal's finding that the character of the funds survives the redesignation so long as the redesignated deposit is made only out of the convertible foreign exchange already lying to the assessee's credit in accounts opened with the original inflow. That is a finding of fact, so the practical lesson is evidential: the chain has to be documented account by account. The second ground is just as useful and is more widely applicable. Section 115C(e) defines a non-resident Indian as an individual, being a citizen of India or a person of Indian origin, who is not a 'resident'; the Court proceeded on the footing that a person who is 'not ordinarily resident' under section 6(6)(a) is not a 'resident' for that purpose and so remains within Chapter XII-A on his own footing — a proposition that is contestable on the text of section 6(6) read with section 2(30), and which no decision above this one was found to support — with the consequence that no section 115H declaration was needed at all, since section 115H is only for a person who has become assessable AS RESIDENT. The Court also refused to let the assessee's own mistaken description of himself as 'Resident' in the return govern, holding that the real status cannot be denied because of a wrong declaration made in ignorance of law. What the assessee did NOT win is worth noting: the Court answered the first three questions, on the validity of the reopening under section 147 and on section 143(2) time limits, IN FAVOUR OF THE REVENUE following the Supreme Court in Rajesh Jhaveri Stock Brokers, so the appeals were only partly allowed.

Binding within that High Court's jurisdiction. Persuasive elsewhere.

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