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Case lawCBDT Circulars & Instructions › Statutory position — s.115H: continuation of the Chapter XII-A benefit after the assessee becomes resident, and the two things it does not cover
CBDT Circulars & InstructionsCuts both wayss.115Hs.115Cs.115C(f)s.115Ds.115Es.115Fs.115-Is.139

Statutory position — s.115H: continuation of the Chapter XII-A benefit after the assessee becomes resident, and the two things it does not cover

My client has returned to India for good and is now assessable as a resident. He holds shares and public-company debentures bought in foreign exchange while he was abroad. Can he keep the twenty per cent rate, and on what?

My client has returned to India for good and is now assessable as a resident. He holds shares and public-company debentures bought in foreign exchange while he was abroad. Can he keep the twenty per cent rate, and on what?

He can, but only on part of it, and only if he files the declaration on time. Section 115H lets a person who was a non-resident Indian in a previous year and becomes assessable as resident in a subsequent year furnish a declaration in writing ALONG WITH his return under section 139 for that assessment year, and the chapter then continues to apply to him until the asset is transferred or converted into money — but the continuation extends only to INVESTMENT INCOME, and only from assets of the nature in sub-clauses (ii), (iii), (iv) and (v) of section 115C(f). Shares in an Indian company, which are sub-clause (i), are not in the list.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 1988-04-01, reported as Income-tax Act, 1961, s.115H, as it stands after the substitution made by the Direct Tax Laws (Amendment) Act 1987 with effect from 1 April 1988. It bears on section 115H, section 115C, section 115C(f), section 115D, section 115E, section 115F, section 115-I, section 139 of the Income Tax Act 1961, in Residence & Treaty Benefit, Capital Gains Exemptions, Deductions & Disallowances and How Tax Law Is Read matters.

Still good law. The Year 2000 and Year 2026 departmental pages print identical operative words, and the same words are reproduced inside High Court judgments of 2005, 2011 and 2012 read in full this pass, so on the material available the section has stood unchanged since 1 April 1988. No Finance Act text was retrieved this pass. The section has been construed by the Kerala High Court in CIT v. Mathew (19 May 2005) — the assessee need not have been assessed as a non-resident in an earlier year — and by the Madras High Court in Dr. M. Manohar v. ACIT (11 July 2011) — the benefit does not extend to income lacking a direct nexus with the foreign exchange asset. Both are carried as separate entries. No decision doubting or overruling either was located this pass, but no systematic later-treatment search was run beyond the indiankanoon queries recorded in NOTES-B84.md. Also located: ACIT v. Prithvish Nag (ITAT Kolkata 'A' Bench, Mahavir Singh, Judicial Member and Waseem Ahmed, Accountant Member, I.T.A. No. 1067/Kol/2013, 6 November 2015, indiankanoon.org/doc/196545914/), which states that a declaration once filed under section 115H need not be repeated in a subsequent year, and then remands for the declaration to be produced; the disposal is 'In the result, Revenue's appeal is allowed for statistical purpose.'

Why it matters

The section is drafted to exclude two things and practitioners are caught by both. First, sub-clause (i) of section 115C(f) — shares in an Indian company — is deliberately omitted from the list in section 115H, so dividend or other investment income from shares does not continue at the concessional rate once the assessee becomes resident, however the shares were funded. What continues is income from debentures of, and deposits with, an Indian company which is not a private company, from Central Government securities within the Public Debt Act 1944, and from assets notified under sub-clause (v). Second, the section speaks only of 'the investment income derived from any foreign exchange asset'. It says nothing about long-term capital gains, so a returning resident who sells a foreign exchange asset does not get the section 115E capital-gains rate through section 115H, and neither the section 115F rollover nor the capital-gains limb travels with him. The machinery is equally unforgiving: the declaration must be in writing, addressed to the Assessing Officer, and furnished ALONG WITH the return under section 139 for the assessment year for which he is first so assessable — in CIT v. N. Sundarraman the Madras High Court records at its paragraph 7 that the ASSESSING OFFICER had found the declaration to have been made much later and not along with the returns, but the Court itself decided the case on a different footing — that the assessee was not a 'resident' at all and so needed no section 115H declaration — and did not decide whether a late declaration can be accepted; and the Madras High Court in Dr. M. Manohar refused to extend the benefit to interest earned on interest that had been re-deposited, because the section requires the income to be derived from the foreign exchange asset itself. The upside is that once the declaration is made the benefit runs on 'for that assessment year and for every subsequent assessment year until the transfer or conversion (otherwise than by transfer) into money of such assets' — it is not an annual election, and it ends only with the asset. On the other side of that question, the ITAT Kolkata in ACIT v. Prithvish Nag, I.T.A. No. 1067/Kol/2013, assessment year 2004-05, order dated 6 November 2015, said in terms that 'once declaration has been filed by assessee u/s 115H of the Act then he does not require to file the same in the subsequent year and assessee will continue to enjoy the benefit given under the provisions of the said section'. The Bench then restored the matter to the Assessing Officer because the declaration had not been produced for verification, so that sentence is the Tribunal's stated construction of the section and not a holding on proved facts — plead it as such.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

Not yet CA-verified. This entry was found through the sources listed under the Sources tab, and the summary reflects what those sources say. Nobody has yet read the full judgment and signed it off. Check the source before relying on it.

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