VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — section 94A: the consequences of dealing with a person located in a notified jurisdictional area, and whether any area is notified today
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Statutory position — section 94A: the consequences of dealing with a person located in a notified jurisdictional area, and whether any area is notified today

My client is remitting money to a company in a low-tax jurisdiction. Does section 94A apply, and is any country actually notified as a notified jurisdictional area at the moment?

My client is remitting money to a company in a low-tax jurisdiction. Does section 94A apply, and is any country actually notified as a notified jurisdictional area at the moment?

Section 94A lets the Central Government notify a country or territory as a notified jurisdictional area having regard to the lack of effective exchange of information, and once notified the consequences are severe and automatic: all parties to a transaction with a person located there are deemed associated enterprises, the transaction is deemed an international transaction so the entire transfer-pricing machinery applies, deductions are barred unless prescribed authorisations and documents are furnished, unexplained receipts from such a person are deemed to be income, and withholding is at the highest of the rate in force, the rate in the relevant provision and thirty per cent. The only notification under section 94A(1) that could be located was Notification No. 86/2013 notifying Cyprus, and it was rescinded by Notification No. 114/2016 with retrospective effect from 1 November 2013. No subsisting notification was found and no departmental list of notified jurisdictional areas could be opened, so nothing here certifies that no jurisdiction is notified today — section 94A should be neither treated as live against a jurisdiction nor written off as a dead letter without checking the current list.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2011-06-01, reported as Income-tax Act, 1961, section 94A, inserted by the Finance Act, 2011. It bears on section 94A, section 94A(1), section 94A(2), section 94A(3), section 94A(4), section 94A(5), section 94A(6), section 92A, section 92B, section 92C, section 92CA, section 92D, section 92E, section 92F, section 195, section 90 of the Income Tax Act 1961, in TDS Defaults, Deductions & Disallowances, Cash Credits & Unexplained Money and How Tax Law Is Read matters.

Still good law. This is the statutory text, not a decision about it. Section 94A was read in full on a departmental page stamped 'Year: 2025' and its sub-sections (1) and (2) cross-read on the 2011-stamped original page, which prints the same words. The constitutional validity of section 94A(1) was upheld by the Madras High Court in W.P.Nos.17241 to 17243 and 17407 to 17412 of 2015 on 12 April 2016; the appeals against that judgment, Civil Appeals Nos. 5159-5167 of 2016, were disposed of by the Supreme Court on 6 January 2017 without any opinion on the merits. On the notification position, the only notification located was Notification No. 86/2013 (Cyprus), rescinded by Notification No. 114/2016 and clarified by Circular No. 15 of 2017 to operate retrospectively from 1 November 2013. No departmental list of currently notified jurisdictional areas could be opened on this pass, so the absence of any subsisting notification is NOT certified.

Why it matters

Section 94A is written as a set of non obstante consequences and every one of them can be triggered by a single payment. Sub-section (2) deems the parties associated enterprises and the transaction international, which pulls in sections 92, 92A, 92B, 92C (except the second proviso to sub-section (2)), 92CA, 92CB, 92D, 92E and 92F — including documentation and the accountant's report, and the exclusion of the second proviso to section 92C(2) means the arm's-length tolerance band is not available. Sub-section (3)(a) makes any payment to a financial institution located in the area non-deductible unless the assessee furnishes a prescribed authorisation permitting the Board to seek information from that institution, and sub-section (3)(b) makes any other expenditure or allowance, including depreciation, non-deductible unless prescribed documents are maintained and information furnished. Sub-section (4) is a deeming provision of the cash-credit type but harsher: a sum received or credited from a person located in the area is deemed to be the assessee's income unless the source is explained in the hands of that person or the beneficial owner. Sub-section (5) fixes withholding at the highest of three rates with a thirty per cent floor and is drafted 'notwithstanding anything contained in any other provisions of this Act'. Sub-section (6) defines 'person located in a notified jurisdictional area' to include a resident of the area, a non-individual established there, and a permanent establishment there of anyone else. The practical point is the last one: none of this operates unless there is a subsisting notification, and the one notification this pass located was withdrawn. An adviser should never imply a jurisdiction is notified without checking, and should equally never assume the section is dead letter, because sub-section (1) can be exercised again at any time.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

Not yet CA-verified. This entry was found through the sources listed under the Sources tab, and the summary reflects what those sources say. Nobody has yet read the full judgment and signed it off. Check the source before relying on it.

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Related

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