VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.10(23FD): the unit holder's exemption for the rest of a business trust distribution, and the s.115BAA switch that decides whether SPV dividend is taxed in his hands
CBDT Circulars & InstructionsCuts both waysValidity unconfirmeds.10(23FD)s.10(23FC)s.10(23FCA)s.115UAs.115UA(2)s.115UA(3)s.115UA(3A)s.115BAAs.194LBAs.194LBA(2A)s.56(2)(xii)Rule 12CA

Statutory position — s.10(23FD): the unit holder's exemption for the rest of a business trust distribution, and the s.115BAA switch that decides whether SPV dividend is taxed in his hands

My client holds units in a listed REIT. The Form 64B shows several components. Which of them does he actually pay tax on, and on what basis is the rest exempt?

My client holds units in a listed REIT. The Form 64B shows several components. Which of them does he actually pay tax on, and on what basis is the rest exempt?

Clause (23FD) of section 10 exempts, in the unit holder's hands, any distributed income referred to in section 115UA received by him from the business trust — but not the proportion of it that is of the same nature as the income referred to in sub-clause (a) of clause (23FC), or clause (23FCA), or sub-clause (b) of clause (23FC) in a case where the special purpose vehicle has exercised the option under section 115BAA. So the interest component and the direct-rent component are always taxable to him; the special purpose vehicle dividend component is taxable to him only if that vehicle is on the concessional corporate rate in section 115BAA, and is otherwise exempt; and everything else the trust distributes out of income that has already borne tax at trust level under section 115UA(2) is exempt. The words carrying the section 115BAA condition were put into the clause by section 7(II)(c) of the Finance Act, 2020 with effect from 1 April 2021.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2021-04-01, reported as Clause (23FD) as inserted by s.5(b) of the Finance (No. 2) Act, 2014 (indiankanoon.org/doc/151046659/), as amended by s.7(III)(e) of the Finance Act, 2015 (indiankanoon.org/doc/127799810/) and by s.7(II)(c) of the Finance Act, 2020 (indiankanoon.org/doc/64850385/); corroborated on incometaxindia.gov.in/w/section-194lba-10 (Year 2024 No. 2). It bears on section 10(23FD), section 10(23FC), section 10(23FCA), section 115UA, section 115UA(2), section 115UA(3), section 115UA(3A), section 115BAA, section 194LBA, section 194LBA(2A), section 56(2)(xii), section Rule 12CA of the Income Tax Act 1961, in Charitable Trusts & Exemption, Capital Gains Exemptions and TDS Defaults matters.

Validity check could not be completed. Validity check could not be completed. The clause could not be read in consolidated form on any departmental page, so its present wording is assembled from three amending Acts read verbatim and cross-checked against the departmental section 194LBA pages of 2019 and 2024 vintage, which turn on the same distinctions. Whether any Finance Act after 2020 has further amended clause (23FD) was not established, and no judicial treatment was searched for.

Why it matters

Clause (23FD) is the provision that stops the same rupee being taxed twice, and its structure is a set of carve-outs rather than a positive grant, so the only safe way to use it is to identify what is carved out and treat the remainder as exempt. Three consequences matter in practice. First, the exemption is not a general exemption for REIT and InvIT distributions: a reader who tells a client that "REIT income is exempt" will be wrong about the interest and the direct-rent components, which are the bulk of most distributions. Second, the section 115BAA condition is a fact about somebody else's tax position. The unit holder cannot work out his own liability without knowing whether the special purpose vehicle has exercised that option, and he has no way of finding out except from the trust's statement. This is the single most common source of a wrong return at the investor's end, and it is why the Form 64B statement under rule 12CA has to break the distribution down properly. Third, the whole clause is keyed to "distributed income referred to in section 115UA", so it has nothing to say about a sum charged under section 56(2)(xii). Section 115UA(3A), inserted by Act No. 8 of 2023 with effect from 1 April 2024, takes such a sum out of the character-retention rule in section 115UA(1) altogether, and it is charged as income from other sources. Do not look for relief for it in clause (23FD). The withholding machinery in section 194LBA is drafted to match the clause exactly, and can be used to check a doubtful reading: sub-section (2A) provides that nothing in sub-sections (1) and (2) applies to income of the nature referred to in sub-clause (b) of clause (23FC) of section 10 if the special purpose vehicle has not exercised the option under section 115BAA — which is the same switch, seen from the deductor's side.

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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