VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.194DA: payment under a life insurance policy, and the date the base changed from the gross sum to the income component
CBDT Circulars & InstructionsCuts both wayss.194DAs.10(10D)s.194D

Statutory position — s.194DA: payment under a life insurance policy, and the date the base changed from the gross sum to the income component

My insurer deducted tax on the whole maturity amount, not on the gain. Was that right, and from what date is s.194DA computed on the income component only?

My insurer deducted tax on the whole maturity amount, not on the gain. Was that right, and from what date is s.194DA computed on the income component only?

The base changed on 1 SEPTEMBER 2019. Until then s.194DA required deduction on the sum paid — two per cent of the sum from 1 October 2014, then one per cent of the sum from 1 June 2016 — with nothing in the text confining it to the gain. From 1 September 2019 the words 'five per cent on the amount of income comprised therein' were substituted for 'one per cent' by Act No. 23 of 2019, and the base has been the income component ever since; the rate then came down from five per cent to two per cent by Act No. 15 of 2024 with effect from 1 October 2024, so the section now requires two per cent on the amount of income comprised in the payment.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2024-10-01, reported as Income-tax Act, 1961, s.194DA, as printed on the departmental page stamped Year 2026. It bears on section 194DA, section 10(10D), section 194D of the Income Tax Act 1961, in TDS Defaults, Capital Gains Exemptions and How Tax Law Is Read matters.

Still good law. Every step in the sequence above is carried by a year-stamped departmental page, and the critical step — the change of base on 1 September 2019 — is established by two pages of the same year stamped (No. 1) and (No. 2) printing the two different texts, plus the footnote on the later one naming the Act and the date. The current text is printed identically on two year-stamped pages — /w/section-194da (Year 2026) and /w/section-194da-12 (Year 2025) — each carrying the same footnote attributing the two per cent rate to Act No. 15 of 2024 with effect from 1 October 2024, and the income-component base is further corroborated on the Year 2022 and Year 2024 (No. 1) pages. No Finance Act text was read this pass and the Act numbers were not matched to Finance Act names independently. Anything applying a five per cent rate to a payment made on or after 1 October 2024, or a gross-sum base to a payment made on or after 1 September 2019, is superseded by amendment.

Why it matters

This is the amendment that decides whether a policyholder is charged on his whole maturity cheque or only on his gain, and getting the date wrong overcharges him badly — on a policy paying ten lakh rupees against premiums of eight lakh, the difference between the gross base and the income base is a factor of five. The dividing line is the date of PAYMENT, not the date the policy was taken or matured. Note the shape of the section carefully: it applies only to a sum under a life insurance policy, including the bonus allocated on it, OTHER THAN the amount not includible in total income under s.10(10D) — so a policy whose proceeds are exempt under s.10(10D) is outside the section entirely, and s.194DA is by design the machinery for the residue that s.10(10D) does not exempt. The threshold has not moved at all: the proviso disapplies deduction where the payment, or the aggregate of payments to the payee during the financial year, is less than one hundred thousand rupees, and that figure appears in identical words on every vintage of the page from Year 2015 to Year 2026. Note also that the proviso uses 'is less than', not 'does not exceed', so a payment of exactly one hundred thousand rupees is within the section.

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.

Read aloud by your device. Press again to stop.

Related

Other authorities on the same sections.