VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — sections 115TCA and 194LBC: the securitisation trust pass-through, and the flat ten per cent withholding from 1 April 2025
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Statutory position — sections 115TCA and 194LBC: the securitisation trust pass-through, and the flat ten per cent withholding from 1 April 2025

Our securitisation trust is distributing to PTC holders. Do we still deduct at twenty-five or thirty per cent, and who is taxed on the trust's income?

Our securitisation trust is distributing to PTC holders. Do we still deduct at twenty-five or thirty per cent, and who is taxed on the trust's income?

No — with effect from 1 April 2025 the Finance Act 2025 substituted the rate in section 194LBC(1) with a flat ten per cent for every resident investor, replacing the earlier twenty-five per cent for an individual or Hindu undivided family and thirty per cent for anyone else; for a non-resident (not being a company) or a foreign company the rate remains 'the rates in force' under sub-section (2). On the charge itself, section 115TCA taxes the income of a securitisation trust in the hands of its investor as if the investments had been made by him directly, with the income retaining its nature and proportion, and deems undistributed income to have been credited to the investor on the last day of the previous year.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2025-04-01, reported as Section 115TCA inserted by the Finance Act, 2016 (Act No. 28 of 2016) with effect from 1 April 2017; section 194LBC inserted by the same Act with effect from 1 June 2016; the rate in section 194LBC(1) substituted by the Finance Act, 2025 (Act No. 7 of 2025) with effect from 1 April 2025. It bears on section 115TCA, section 194LBC, section 10(23DA), section 201, section 201(1A) of the Income Tax Act 1961, in TDS Defaults, Charitable Trusts & Exemption, How Tax Law Is Read and Assessment & Scrutiny matters.

Still good law. The ten per cent rate and the substitution footnote were read on the department's section 194LBC page carrying the current 'Year: 2026' stamp, the correct heading 'Income in respect of investment in securitization trust' and the Act name 'Income-tax Act, 1961'; three other departmental pages for the same section, stamped Year 2024 (No. 2), Year 2018 and Year 2016, print the superseded twenty-five and thirty per cent rates and were used only to establish what the earlier text was. Section 115TCA was read in full on two departmental pages stamped Year 2024 (No. 2) and Year 2022 which agree word for word, and the section and Explanation are also reproduced in the Departmental Representative's written submissions recorded verbatim in the Mumbai Tribunal's order in SME Pool Series V August 2016 v. ITO (TDS) (ITA Nos. 341 and 342/Mum/2023, pronounced 21 February 2024). Whether any Finance Act after 2016 has amended section 115TCA itself could not be established because the footnote block on the current pages was not reached.

Why it matters

The rate change is large, recent and easy to miss: a trust that carried on deducting thirty per cent after 1 April 2025 has over-withheld by twenty percentage points on every corporate investor, and the investors' only remedy is a refund claim through their own returns. The other half of the section that repays attention is the definition of 'investor'. Section 194LBC borrows it from clause (a) of the Explanation after section 115TCA, where it means a person who is the holder of a securitised debt instrument, securities or a security receipt issued by the securitisation trust — a holding-based test. That is what the Mumbai Tribunal applied in SME Pool Series V August 2016 to hold that an originator who met its Minimum Retention Requirement by cash collateral rather than by subscribing to pass-through certificates is not an 'investor', so excess interest spread paid to it attracted no deduction. On the charging side, section 115TCA(3) deems income not paid or credited to have been credited on the last day of the previous year, and sub-section (5) prevents that income being taxed again when it is actually paid — so the investor's return is driven by accrual at trust level and by the statement furnished under sub-section (4), not by cash received.

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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