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Case lawCBDT Circulars & Instructions › Statutory position — s.10(2): a member's receipt out of family income is exempt, but the clause is subject to s.64(2) and is overridden by s.171(4)(b)
CBDT Circulars & InstructionsCuts both wayss.10(2)s.10s.64(2)s.171(4)

Statutory position — s.10(2): a member's receipt out of family income is exempt, but the clause is subject to s.64(2) and is overridden by s.171(4)(b)

My client received money from his family HUF during the year. The Assessing Officer wants to tax it in his hands. Is it exempt, and if so is there anything that can take the exemption away?

My client received money from his family HUF during the year. The Assessing Officer wants to tax it in his hands. Is it exempt, and if so is there anything that can take the exemption away?

Section 10(2) exempts, in computing the total income of a previous year of any person, "any sum received by an individual as a member of a Hindu undivided family, where such sum has been paid out of the income of the family, or, in the case of any impartible estate, where such sum has been paid out of the income of the estate belonging to the family". Two qualifications sit on the face of the Act and both are routinely missed. The clause opens with the words "subject to the provisions of sub-section (2) of section 64", so where the family's income is itself income the individual is deemed to derive under the conversion rules of s.64(2), the exemption gives him nothing. And s.171(4)(b) imposes joint and several liability on members for tax on the family's income up to the date of a recorded partition expressly "notwithstanding anything contained in clause (2) of section 10".

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 1962-04-01, reported as Income-tax Act, 1961, s.10(2), as printed on the departmental Year 2024 (No. 2) and Year 2007 pages. It bears on section 10(2), section 10, section 64(2), section 171(4) of the Income Tax Act 1961, in Capital Gains Exemptions, Assessment & Scrutiny and How Tax Law Is Read matters.

Still good law. Two departmental editions (Year 2007 and Year 2024 (No. 2)) print clause (2) in identical words, differing only in a closing semicolon. No amendment footnote for the clause was read, so no commencement date is asserted. I did not carry out a check of judicial treatment of s.10(2) on this pass; the library already holds three Tribunal decisions tagged to it and this entry states the statutory text and its two express cross-references only.

Why it matters

The exemption is narrower than practitioners treat it. Its own words require three things: the recipient must be an individual, he must receive as a MEMBER of the family, and the sum must have been paid OUT OF THE INCOME of the family (or, for an impartible estate, out of the income of the estate belonging to the family). Nothing in the clause exempts a sum paid out of the family's capital or corpus, and nothing in it exempts a receipt by someone who is not a member. The two cross-references matter more still. The opening words make the exemption subordinate to s.64(2): if an individual converted his separate property into family property and the family's income from that property is deemed by s.64(2)(b) to arise to him and not to the family, he cannot then take a distribution of that same income and call it exempt under s.10(2). Section 171(4)(b) works the other way round — it is drafted to override s.10(2) — so a member who has taken money out of the family cannot use the exemption as a shield against the joint and several liability for the family's tax up to the date of partition. The library already carries the Tribunal authorities on the receipt side of this clause (Vinitkumar Raghavjibhai Bhalodia, Pankil Garg, Gyanchand M. Bardia); what it did not carry was the statutory text and its two express qualifications.

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

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Related

Other authorities on the same sections.