VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.115E: twenty per cent on investment income throughout, and long-term capital gains at ten per cent before 23 July 2024 and twelve and one-half per cent on or after it
CBDT Circulars & InstructionsCuts both wayss.115Es.115Cs.115C(b)s.115Ds.115Fs.115-Is.45s.48

Statutory position — s.115E: twenty per cent on investment income throughout, and long-term capital gains at ten per cent before 23 July 2024 and twelve and one-half per cent on or after it

My NRI client sold shares of an Indian company that he had subscribed to in foreign exchange. The transfer was in September 2024. My software has computed the tax at ten per cent under section 115E. Which rate applies, and from when did it change?

My NRI client sold shares of an Indian company that he had subscribed to in foreign exchange. The transfer was in September 2024. My software has computed the tax at ten per cent under section 115E. Which rate applies, and from when did it change?

Twelve and one-half per cent, because the transfer took place on or after 23 July 2024. Section 115E(ii) now splits the long-term capital gains rate — ten per cent for any transfer which takes place before the 23rd day of July, 2024, and twelve and one-half per cent for any transfer on or after that date — while the rate on investment income under s.115E(i) remains twenty per cent and has done since 1 April 1998.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2024-07-23, reported as Income-tax Act, 1961, s.115E, as clause (ii) was substituted with retrospective effect from 23 July 2024. It bears on section 115E, section 115C, section 115C(b), section 115D, section 115F, section 115-I, section 45, section 48 of the Income Tax Act 1961, in Capital Gains, Residence & Treaty Benefit, Capital Gains Exemptions and How Tax Law Is Read matters.

Still good law. The Year 2025 and Year 2026 departmental pages print identical split-rate text with footnotes in the same terms, which is the strongest evidence available on this pass that nothing has displaced the 23 July 2024 position. No Finance Act text was retrieved this pass and the amending statute is recorded only by its number, Act No. 15 of 2024. Any authority, opinion, computation or software setting applying ten per cent to a transfer on or after 23 July 2024 is superseded by amendment, and any authority applying a single flat twenty per cent to long-term capital gains is superseded for any period from 1 April 1998.

Why it matters

The rate in this section is keyed to the DATE OF TRANSFER, not to the previous year or the assessment year, so a single assessment year straddles both rates and a return for AY 2025-26 may legitimately carry ten per cent on one sale and twelve and one-half per cent on another. That is unusual drafting and it is where the arithmetic errors are. Three further features of the section are missed. First, the rate on investment income is twenty per cent and is charged on the GROSS income, because s.115D(1) forbids any deduction against it. Second, s.115E(iii) preserves the ordinary charge on the rest of the total income by taxing it as if the total income had been reduced by the amounts in clauses (a) and (b), so the special rates are ring-fenced and do not spill over. Third, the section as it has stood since 1 April 1998 is oddly drafted: clause (a) reaches 'any income from investment or income from long-term capital gains of an asset other than a specified asset' at twenty per cent, and clause (b) reaches 'income by way of long-term capital gains' at the capital-gains rate — the Tribunal's reading in Deivanayagam Maruthini (ITAT Chennai, 28 February 2012) is that by implication the long-term capital gains in clause (b) are those arising on a specified asset. Before 1 April 1998 the section had a wholly different shape: a single flat twenty per cent where the total income consisted only of investment income or long-term capital gains or both, which is the text the older decisions construe and which must not be quoted for a current year. And the section only ever engages where the underlying asset is a 'foreign exchange asset' within s.115C(b) — the rate is worthless if the convertible-foreign-exchange condition is not proved.

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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