VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — section 115UA: what a REIT or InvIT passes through, what it pays at the maximum marginal rate, and the 2023 carve-out
CBDT Circulars & InstructionsCuts both wayss.115UAs.115UA(3A)s.10(23FC)s.10(23FCA)s.56(2)(xii)s.194LBAs.2(13A)s.111As.112

Statutory position — section 115UA: what a REIT or InvIT passes through, what it pays at the maximum marginal rate, and the 2023 carve-out

My client holds units in a listed REIT. Which part of what the trust distributes is taxable in his hands, and what does the trust itself pay tax on?

My client holds units in a listed REIT. Which part of what the trust distributes is taxable in his hands, and what does the trust itself pay tax on?

Section 115UA(1) makes the distributed income of a business trust retain, in the unit holder's hands, the same nature and proportion it had in the trust's, and section 115UA(3) charges to tax in the unit holder's hands the distributed income which is of the nature referred to in clause (23FC) or clause (23FCA) of section 10 — broadly, interest and dividend from the special purpose vehicle, and rent from directly held property. Everything else forming the trust's own total income is charged in the trust's hands at the maximum marginal rate under section 115UA(2), subject to sections 111A and 112; and since 1 April 2024 sub-section (3A) removes the character-retention rule altogether for a sum charged under section 56(2)(xii).

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2015-04-01, reported as Chapter XII-FA, consisting of section 115UA, inserted by the Finance (No. 2) Act, 2014 (Act No. 25 of 2014) with effect from 1 April 2015; the words "or clause (23FCA)" inserted in sub-section (3) by the Finance Act, 2015 (Act No. 20 of 2015) with effect from 1 April 2016; the words "sub-clause (a) of" inserted in sub-section (3) by the Finance Act, 2016 (Act No. 28 of 2016) with effect from 1 April 2017 and omitted from it by the Finance Act, 2020 (Act No. 12 of 2020) with effect from 1 April 2021; sub-section (3A) inserted by the Finance Act, 2023 (Act No. 8 of 2023) with effect from 1 April 2024. It bears on section 115UA, section 115UA(3A), section 10(23FC), section 10(23FCA), section 56(2)(xii), section 194LBA, section 2(13A), section 111A, section 112 of the Income Tax Act 1961, in Charitable Trusts & Exemption, Capital Gains Exemptions, Capital Gains, How Tax Law Is Read and TDS Defaults matters.

Still good law. The present text of section 115UA, including sub-section (3A), was read in full on three departmental pages carrying different 'Year:' stamps — Year 2023, Year 2024 (No. 1) and Year 2024 (No. 2) — which agree word for word, and the Bangalore Tribunal in Embassy Office Parks REIT v. DCIT (ITA No. 221/Bang/2025, pronounced 8 July 2026) describes the same scheme at its paragraphs 19 and 26. The insertion of Chapter XII-FA by Act No. 25 of 2014 with effect from 1 April 2015, and of sub-section (3A) by Act No. 8 of 2023 with effect from 1 April 2024, were read from departmental footnotes. No page stamped Year 2025 or Year 2026 for this section was located this pass, so a Finance Act 2025 or 2026 amendment has not been ruled out. The words of sections 10(23FC), 10(23FCA) and 10(23FD) were not read and are not stated here.

Why it matters

Practitioners repeatedly get this backwards by treating the trust as an exempt entity. It is not. Section 115UA(2) is a charging provision on the trust at the maximum marginal rate, and it bites on any income of the trust that is not carved out — a capital gain on the sale of an SPV holding, for example, is taxed in the trust's hands under section 115UA(2) read with sections 111A and 112, and reaches the unit holder as a distribution the character of which is preserved but which has already borne tax at trust level. The pass-through in sub-section (3) is confined to two clauses of section 10 and no more. Three drafting points then decide most computations. First, sub-section (3) as it now stands refers to the WHOLE of clause (23FC) and not to sub-clause (a) alone — earlier versions of the section, still visible on archived departmental pages stamped Year 2016 to Year 2019, read 'sub-clause (a) of clause (23FC)', which confined the pass-through to interest and left dividend outside it while dividend distribution tax was in force. Any computation for AY 2021-22 onwards must use the present wording. Second, sub-section (1) works on 'distributed income', so it operates on what is paid out and not on what the trust merely earns. Third, sub-section (4) obliges the payer to furnish a statement to the unit holder and to the prescribed authority — rules 12CA and Forms 64A and 64B — and that statement is the document from which the unit holder's return is built.

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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