VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — section 10(38): the third proviso, Notification 43/2017 and the 1 April 2018 sunset
CBDT Circulars & InstructionsCuts both waysSuperseded by amendments.10(38)s.112As.55(2)(ac)s.47s.50B

Statutory position — section 10(38): the third proviso, Notification 43/2017 and the 1 April 2018 sunset

The assessing officer says my client's long-term gains on listed shares are not exempt under section 10(38) because no STT was paid when the shares were bought. Is that right, and does section 10(38) even apply to my year?

The assessing officer says my client's long-term gains on listed shares are not exempt under section 10(38) because no STT was paid when the shares were bought. Is that right, and does section 10(38) even apply to my year?

First check the year: section 10(38) does not apply at all to a transfer made on or after 1 April 2018, because the Finance Act 2018 inserted a fourth proviso switching the clause off from that date — so for AY 2019-20 onwards the question is section 112A, not section 10(38). For a transfer up to 31 March 2018, the third proviso (inserted by the Finance Act 2017) does require STT to have been paid on ACQUISITION as well, but only in the cases carved out by the Central Government's Notification No. 43/2017 (S.O. 1789(E)) dated 5 June 2017 — the notification's main part covers all acquisitions of equity shares from 1 October 2004 that were not chargeable to STT, and only its three listed clauses take an acquisition out of the exemption.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2017-06-05, reported as S.O. 1789(E), Notification No. 43/2017, F. No. 370142/09/2017-TPL, dated 5 June 2017; section 5(b)(iii) of the Finance Act, 2018. It bears on section 10(38), section 112A, section 55(2)(ac), section 47, section 50B of the Income Tax Act 1961, in Capital Gains, Capital Gains Exemptions and How Tax Law Is Read matters.

Superseded by amendment. Section 10(38) is spent for transfers made on or after 1 April 2018; section 112A applies instead from that date. The position stated here remains the operative law for transfers up to 31 March 2018 and for the assessments and appeals still running on those years. Notification 43/2017 was read only as reproduced in a July 2024 Tribunal order; the gazette text itself was not retrieved and no check was made for a later amending notification.

Why it matters

The notification is drafted the wrong way round from how officers read it. It notifies ALL acquisitions not chargeable to STT as covered, and then excepts three classes: (a) a preferential issue in a company whose shares are not frequently traded, (b) an acquisition of an EXISTING LISTED equity share not entered through a recognised stock exchange, and (c) an acquisition during a company's delisted period. Each of (a) and (b) has its own proviso restoring the exemption for specified regular acquisitions. So an off-market purchase does not by itself defeat section 10(38) — the officer must place the acquisition inside one of the three clauses, and clauses (a) to (c) all speak of listed shares, which is why they cannot reach a purchase of shares that were unlisted when acquired.

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