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Case lawCBDT Circulars & Instructions › Statutory position — s.115C: the Chapter XII-A definitions, and the convertible-foreign-exchange condition that the whole chapter turns on
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Statutory position — s.115C: the Chapter XII-A definitions, and the convertible-foreign-exchange condition that the whole chapter turns on

My client is a person of Indian origin living in Dubai. He bought shares in an Indian listed company out of rupees lying in his NRO account. The assessing officer says Chapter XII-A does not apply to him at all and has taxed the gain at the ordinary rate. Is he right?

My client is a person of Indian origin living in Dubai. He bought shares in an Indian listed company out of rupees lying in his NRO account. The assessing officer says Chapter XII-A does not apply to him at all and has taxed the gain at the ordinary rate. Is he right?

On these facts, yes — and the reason is the funding, not the status. Section 115C(b) defines a "foreign exchange asset" as any specified asset "which the assessee has acquired or purchased with, or subscribed to in, convertible foreign exchange", so an asset bought out of rupee funds is not a foreign exchange asset, and nothing in Chapter XII-A — not s.115E, not s.115F, not s.115H — can reach it. Being a non-resident Indian within s.115C(e) is a necessary condition but never a sufficient one.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2021-04-01, reported as Income-tax Act, 1961, s.115C, as it stands after the omission of the words 'other than dividends referred to in section 115-O' with effect from 1 April 2021. It bears on section 115C, section 115C(a), section 115C(b), section 115C(c), section 115C(d), section 115C(e), section 115C(f), section 115D, section 115E, section 115F, section 115G, section 115H, section 115-I, section 6, section 2(42A) of the Income Tax Act 1961, in Residence & Treaty Benefit, Capital Gains, Capital Gains Exemptions and How Tax Law Is Read matters.

Still good law. The Year 2024 (No. 1) and Year 2026 departmental pages print identical operative words, which is the strongest evidence available on this pass that nothing has displaced the position established when the s.115-O dividend carve-out was omitted with effect from 1 April 2021. That is not the same as reading the current Finance Act: no Finance Act text was retrieved this pass, and the amending statute is recorded only by the number the departmental footnote gives it, Act No. 12 of 2020. Any authority or software setting that applies the dividend carve-out in s.115C(c) to a year after AY 2020-21 is superseded by amendment, and any submission citing the Foreign Exchange Regulation Act 1973 in s.115C(a) for a period on or after 1 April 2013 is likewise out of date.

Why it matters

Chapter XII-A has two independent gates and practitioners routinely argue only the first. The first gate is the person: s.115C(e) defines "non-resident Indian" as an individual, being a citizen of India or a person of Indian origin, who is not a "resident" — and the Explanation deems a person to be of Indian origin if he, or either of his parents, or any of his grand-parents, was born in undivided India, which reaches a great many second and third generation families. The second gate is the asset, and it is the one that is failed. Section 115C(f) contains a CLOSED list of five "specified assets": shares in an Indian company; debentures issued by an Indian company which is not a private company; deposits with an Indian company which is not a private company; any security of the Central Government as defined in s.2(2) of the Public Debt Act 1944; and such other assets as the Central Government may specify by notification. Immovable property is not in that list. Bank deposits with a bank are not "deposits with an Indian company" unless the bank is an Indian company that is not a private company. Debentures of, and deposits with, a private company are expressly outside it. And even an asset that is on the list becomes a "foreign exchange asset" only if s.115C(b) is satisfied — acquired or purchased with, or subscribed to in, convertible foreign exchange. "Convertible foreign exchange" is not defined by the tax statute at large: s.115C(a) borrows the Reserve Bank of India's treatment of it for the purposes of the Foreign Exchange Management Act 1999 and the rules made thereunder, and before 1 April 2013 the same clause referred to the Foreign Exchange Regulation Act 1973. Two further definitions do the work downstream: "investment income" in s.115C(c) is any income derived from a foreign exchange asset — the qualification "other than dividends referred to in section 115-O" has now gone, omitted with effect from 1 April 2021 when the dividend distribution tax was dismantled — and "long-term capital gains" in s.115C(d) is income under the head Capital gains relating to a capital asset being a foreign exchange asset which is not a short-term capital asset. Read together, that is why the documentary trail of the remittance, and not the client's passport, is what decides these cases.

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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