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Case lawCBDT Circulars & Instructions › Statutory position — s.115R, s.115S and s.115T: tax on income distributed by a mutual fund or UTI, the exemptions in the provisos to s.115R(2), and the deemed assessee in default
CBDT Circulars & InstructionsCuts both waysSuperseded by amendments.115Rs.115R(2)s.115R(2A)s.115R(3)s.115Ss.115Ts.10(23D)s.112A

Statutory position — s.115R, s.115S and s.115T: tax on income distributed by a mutual fund or UTI, the exemptions in the provisos to s.115R(2), and the deemed assessee in default

My client is a mutual fund trustee and has a demand for tax on income distributed to unit holders for a year before 2020. What rate applied to which kind of fund, what was exempt, and who is in default?

My client is a mutual fund trustee and has a demand for tax on income distributed to unit holders for a year before 2020. What rate applied to which kind of fund, what was exempt, and who is in default?

Section 115R(2) charged a specified company or a Mutual Fund to additional income-tax on income distributed to its unit holders on or before 31 March 2020, at twenty-five per cent where distributed to an individual or HUF by a money market mutual fund or a liquid fund, thirty per cent to any other person by such a fund, ten per cent to any person by an equity oriented fund, twenty-five per cent to an individual or HUF by any other fund, and thirty per cent to any other person by any other fund; sub-section (2A) grosses the distributed income up. Section 115S charges simple interest at one per cent a month for late payment of the s.115R tax, and s.115T deems the person responsible, and the specified company or Mutual Fund, to be an assessee in default with the whole recovery machinery applying.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2020-04-01, reported as Income-tax Act, 1961, ss.115R, 115S and 115T, as printed on the departmental pages stamped Year: 2026, with s.115R corroborated on the page stamped Year: 2025. It bears on section 115R, section 115R(2), section 115R(2A), section 115R(3), section 115S, section 115T, section 10(23D), section 112A of the Income Tax Act 1961, in How Tax Law Is Read and Demand, Recovery & Stay matters.

Superseded by amendment. Section 115R(2) charges nothing on income distributed after 31 March 2020, and s.115R(1) nothing after 31 March 2002, so the Chapter is spent prospectively; it remains the operative law for the years this library covers up to FY 2019-20 and for the recovery and appeals flowing from them. The Year 2026 and Year 2025 texts of s.115R are identical. No case law under s.115R, s.115S or s.115T was searched for this pass, and no commencement date could be sourced because the departmental pages carry no footnote list.

Why it matters

The library has had nothing at all on s.115R, and the section is unusually easy to misapply because the rate turns on two variables at once — the class of fund and the class of unit holder — and because the exemptions sit in three separate provisos with three different shapes. The first proviso is a rate override, not an exemption: where income is distributed by a mutual fund under an infrastructure debt fund scheme to a non-resident (not being a company) or a foreign company, the rate is five per cent. The second proviso is a true exemption, but only one of its two limbs survives on the current text: clause (a) exempts income distributed by the Administrator of the specified undertaking to unit holders, and clause (b) is printed as omitted — '[***]'. That omitted clause (b) is the reason a great deal of older writing says equity oriented funds were exempt: on the text as it now stands they are not exempt but are charged at ten per cent under clause (iii) of sub-section (2). Which of the two positions applies to a given year has to be settled on the text in force in that year, and the departmental pages carry no footnote list from which the change can be dated. The third proviso is a narrow IFSC exemption: no additional income-tax on income distributed on or after 1 September 2019 by a specified Mutual Fund out of income derived from transactions on a recognised stock exchange located in an International Financial Services Centre where the consideration is paid or payable in convertible foreign exchange, and 'specified Mutual Fund' is defined in the Explanation as a s.10(23D) fund located in an IFSC all of whose units are held by non-residents. Sub-section (1) is a separate and older charge, on income distributed on or before 31 March 2002 by the Unit Trust of India, at ten per cent, with its own three-year proviso for open-ended equity oriented funds running from 1 April 1999. Sub-section (2A) is the grossing-up, in the same form as s.115-O(1B). Sub-section (3) gives fourteen days from the date of distribution or payment, whichever is earlier — note that this is a different formula from s.115-O(3), which runs from the earliest of declaration, distribution and payment. Sub-section (4) bars any other deduction to the UTI or the Mutual Fund in respect of the income charged. Sub-section (3A) is printed as omitted. Section 115T's Explanation is where the definitions for the whole Chapter live: 'Mutual Fund' means a fund specified under s.10(23D); 'equity oriented fund' means a fund referred to in clause (a) of the Explanation to s.112A and the Unit Scheme, 1964 of the Unit Trust of India; 'money market mutual fund' and 'liquid fund' take their meanings from the SEBI (Mutual Funds) Regulations, 1996. So the classification fight is a SEBI-classification fight, decided on the scheme's regulatory classification, not on the fund's actual portfolio.

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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