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Case lawCBDT Circulars & Instructions › Statutory position — s.102: "tax benefit", "arrangement", "step", "party" and "benefit" — the definitions that decide whether Chapter X-A can start at all
CBDT Circulars & InstructionsCuts both wayss.102s.102(1)s.102(3)s.102(6)s.102(9)s.102(10)s.102(11)s.95s.96s.97Rule 10U

Statutory position — s.102: "tax benefit", "arrangement", "step", "party" and "benefit" — the definitions that decide whether Chapter X-A can start at all

The department says I obtained a "tax benefit" from an "arrangement". Where are those words defined, how wide are they, and does an increase in my carried-forward loss count?

The department says I obtained a "tax benefit" from an "arrangement". Where are those words defined, how wide are they, and does an increase in my carried-forward loss count?

Section 102 is the definition section for the whole Chapter, and its two most important entries are drafted as wide as they could be. "Tax benefit" in s.102(10) is an INCLUSIVE definition — the section says "includes" — and its six sub-clauses cover a reduction, avoidance or deferral of tax or other amount payable under the Act; an increase in a refund; the same two things where they arise as a result of a tax treaty; a reduction in total income; and an increase in loss — each of them "in the relevant previous year or any other previous year". An increase in loss therefore is a tax benefit even in a year in which no tax was payable at all. "Arrangement" in s.102(1) means "any step in, or a part or whole of, any transaction, operation, scheme, agreement or understanding, whether enforceable or not", and includes the alienation of property in it, and "step" in s.102(9) includes "a measure or an action, particularly one of a series taken in order to deal with or achieve a particular thing or object in the arrangement".

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2018-04-01, reported as Section 102 of the Income-tax Act, 1961, transcribed from incometaxindia.gov.in/w/section-102-1 (heading "Definitions", Year: 2013) and confirmed clause for clause against section 102 of the Finance Act, 2013 (Act 17 of 2013) at indiankanoon.org/doc/170188709/; the superseded Finance Act 2012 text read on incometaxindia.gov.in/w/section-102 (Year: 2012). It bears on section 102, section 102(1), section 102(3), section 102(6), section 102(9), section 102(10), section 102(11), section 95, section 96, section 97, section Rule 10U of the Income Tax Act 1961, in How Tax Law Is Read and Assessment & Scrutiny matters.

Still good law. The Finance Act 2013 text is the one in force so far as I could establish: it is printed on a departmental page stamped Year 2013, matches the substituting Finance Act provision clause for clause on an independent site, and is the numbering to which Rule 10U(3)(iv) cross-refers. Suffixes above /w/section-102-1 were not probed, so a later version cannot be excluded on this evidence. The conflict with a fragment of the Supreme Court's judgment in the Tiger Global appeal, which reproduces the superseded 2012 numbering, is set out in the editor note and has not been resolved; a reader relying on clause numbers should take them from the Finance Act 2013 text. No other check of judicial treatment was made.

Why it matters

The definitions are where the Chapter is won or lost before the merits start. First, "includes" rather than "means": the Finance Act 2012 version of the definition opened "tax benefit means" and had five sub-clauses; the version in force opens "tax benefit includes" and has six, having split the old fifth sub-clause into "a reduction in total income" and "an increase in loss". The consequence is that the six sub-clauses are illustrative, not exhaustive, so an argument that a particular advantage falls outside all six will not by itself defeat the Chapter. Second, the words "in the relevant previous year or any other previous year" mean the benefit does not have to arise in the year under assessment; a deferral into a later year is expressly a tax benefit. Third, the width of "arrangement" — "whether enforceable or not", and expressly including a single step — is what allows the Explanation to s.95 and the presumption in s.96(2) to operate at step level. There is no requirement of a legally binding document. Fourth, and often decisive on the threshold, Rule 10U(3)(iv) tells you HOW to quantify the tax benefit for the three crore rupee exclusion: for sub-clauses (a) to (e) it is the amount of tax, and for sub-clause (f), an increase in loss, it is the tax that would have been chargeable had the increase in loss been the total income. That cross-reference to "clause (10) of section 102" and to "sub-clause (f)" is itself confirmation that the numbering in force is the Finance Act 2013 numbering set out here. Fifth, "party" in s.102(6) INCLUDES a permanent establishment, so a PE can be a party to an arrangement in its own right; and "benefit" in s.102(3) includes a payment of any kind, tangible or intangible.

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

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