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Case lawCBDT Circulars & Instructions › Statutory position — s.115G: no return need be furnished where the only income is investment income or long-term capital gains and tax has been deducted at source
CBDT Circulars & InstructionsCuts both wayss.115Gs.115Cs.115Ds.115Es.115Hs.139s.139(1)s.271(1)(c)

Statutory position — s.115G: no return need be furnished where the only income is investment income or long-term capital gains and tax has been deducted at source

My NRI client's only Indian income for the year was interest on debentures of an Indian public company subscribed to in foreign exchange, and the company deducted tax at source. He did not file a return and has now had a notice. Was he obliged to file?

My NRI client's only Indian income for the year was interest on debentures of an Indian public company subscribed to in foreign exchange, and the company deducted tax at source. He did not file a return and has now had a notice. Was he obliged to file?

If both conditions in section 115G are satisfied, no. It is not necessary for a non-resident Indian to furnish a return under section 139(1) if his total income assessable under the Act during the previous year consisted ONLY of investment income or long-term capital gains or both, AND the tax deductible at source under Chapter XVII-B has been deducted from that income.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 1983-06-01, reported as Income-tax Act, 1961, s.115G, as inserted with Chapter XII-A by the Finance Act 1983 with effect from 1 June 1983. It bears on section 115G, section 115C, section 115D, section 115E, section 115H, section 139, section 139(1), section 271(1)(c) of the Income Tax Act 1961, in Residence & Treaty Benefit, TDS Defaults, Assessment & Scrutiny and Refunds, Interest & Condonation matters.

Still good law. The Year 2000 and Year 2026 departmental pages print identical text under an identical heading and neither carries any amendment footnote, which is the best evidence available on this pass that the section has not been amended since it was inserted with effect from 1 June 1983. No Finance Act text was retrieved this pass. Section 115G was applied by the ITAT Mumbai in Rita Hemchand Gandhi v. ITO (International Taxation) Ward 2(3)(1), I.T.A. No. 50/Mum/2024, order pronounced 21 June 2024, to delete a penalty under section 271(1)(c) on a non-resident who had not filed a return. That order does not construe the section against a competing construction, and no decision doing so was located.

Why it matters

This is relief people do not know they have, and it is also relief that is easy to lose. The two conditions are cumulative and both are strict. 'Consisted only of' means exactly that: a single item of other Indian income — rent from a flat, a savings bank interest credit, a small dividend from an asset not acquired in convertible foreign exchange — takes the year outside the section and revives the ordinary section 139(1) obligation for the whole year. And it is the tax DEDUCTIBLE under Chapter XVII-B that must have been deducted, so a short deduction, or a deduction the payer never made, defeats the section however innocent the assessee. Two limits deserve to be stated plainly. First, s.115G excuses the FURNISHING of a return under s.139(1); it does not extinguish the charge, and it does not by itself answer a notice under s.142(1) or s.148 calling for a return. Second, the relief is worth nothing where the client wants a refund of excess deduction or wants to claim a treaty rate — a return is the only route to either, and filing voluntarily is usually the better course. Where the client also wants the benefit of the chapter to continue after he becomes resident, note that s.115H requires a declaration to be furnished ALONG WITH the return under s.139, so an assessee who relies on s.115G and files nothing has no return to attach the declaration to. One decision shows the section doing real work. In Rita Hemchand Gandhi v. ITO (International Taxation), Mumbai (ITAT Mumbai, order pronounced 21 June 2024), a non-resident whose only income was interest, on which the payer had deducted at ten per cent instead of the twelve and one-half per cent treaty rate, filed no return in reliance on section 115G; when the shortfall was detected on reopening she paid the balance immediately and the assessment was made at the returned figure. The Tribunal deleted the section 271(1)(c) penalty, holding that the error was the deductor's and not the assessee's. The case is an answer to a penalty rather than to the charge, and that is how it should be pleaded.

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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