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Case lawCBDT Circulars & Instructions › Statutory position — s.10(23FCA): a REIT's exemption for rent from real estate it owns directly, and why an InvIT cannot use it
CBDT Circulars & InstructionsCuts both waysValidity unconfirmeds.10(23FCA)s.10(23FC)s.10(23FD)s.115UAs.115UA(2)s.115UA(3)s.194LBAs.194LBA(3)s.2(13A)Rule 12CA

Statutory position — s.10(23FCA): a REIT's exemption for rent from real estate it owns directly, and why an InvIT cannot use it

My client is a registered REIT that owns some office buildings directly rather than through a project company, and lets them out. Is that rent taxed in the REIT's hands at the maximum marginal rate?

My client is a registered REIT that owns some office buildings directly rather than through a project company, and lets them out. Is that rent taxed in the REIT's hands at the maximum marginal rate?

No. Clause (23FCA) of section 10 keeps out of a business trust's total income any income of a business trust, being a real estate investment trust, by way of renting or leasing or letting out any real estate asset owned directly by such business trust. The clause was inserted by section 7(III)(d) of the Finance Act, 2015 with effect from 1 April 2016, and "real estate asset" takes the meaning given to it in clause (zj) of sub-regulation (1) of regulation 2 of the SEBI (Real Estate Investment Trusts) Regulations, 2014. Two limits are on the face of it: the trust must be a real estate investment trust, so an InvIT cannot use the clause; and the asset must be owned directly by the trust, so rent earned by a special purpose vehicle and passed up as interest or dividend is on a different clause altogether.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2016-04-01, reported as Clause (23FCA) as inserted by section 7(III)(d) of the Finance Act, 2015 (indiankanoon.org/doc/127799810/); cross-referred on incometaxindia.gov.in/w/section-194lba-10 (Year 2024 No. 2) and /w/section-194lba-5 (Year 2019 No. 2). It bears on section 10(23FCA), section 10(23FC), section 10(23FD), section 115UA, section 115UA(2), section 115UA(3), section 194LBA, section 194LBA(3), section 2(13A), section Rule 12CA of the Income Tax Act 1961, in Charitable Trusts & Exemption, Capital Gains Exemptions and House Property matters.

Validity check could not be completed. Validity check could not be completed. The clause is quoted from the enacting words of the Finance Act, 2015, not from a consolidated departmental page, because nine departmental section 10 URLs were fetched and none reached this clause; the furthest any of them reached was clause (23DA), on the pages stamped Year 2017, Year 2018 and Year 2019 (No. 1). That the clause remains in force and continues to describe a distinct income stream is confirmed by the departmental section 194LBA page stamped Year 2024 (No. 2), which prescribes a separate rate for it. Whether the clause has been amended since 2015 was not established, and no judicial treatment was searched for.

Why it matters

Clause (23FCA) exists because the 2014 regime assumed a REIT would hold everything through special purpose vehicles, and the SEBI regulations then allowed direct ownership. Without this clause direct rent would sit in the trust's total income and be charged under section 115UA(2) at the maximum marginal rate, and would be exempt in the unit holder's hands under section 10(23FD) — the worst of both worlds. The clause reverses that: rent from directly held property is out of the trust's income, and section 115UA(3) then charges it in the unit holder's hands, because section 10(23FD) expressly excludes income of the nature referred to in clause (23FCA) from the unit holder's exemption. The withholding follows: section 194LBA(1) deducts ten per cent from a resident unit holder on the clause (23FCA) stream as it does on the clause (23FC) stream, but section 194LBA(3) deals with the clause (23FCA) stream paid to a non-resident or foreign company separately and at "the rates in force", not at the five per cent that applies to the interest limb. That distinction between a fixed rate and rates in force is a common error in REIT withholding, and it is worth reading the two sub-sections side by side before certifying a deduction. Note also what the clause does not do. It says nothing about capital gains on the sale of a directly held asset, which stay in the trust's total income under section 115UA(2), read with sections 111A and 112; and it says nothing about a distribution that is repayment of debt, which since 1 April 2024 is caught in the unit holder's hands by section 56(2)(xii).

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