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Case lawCBDT Circulars & Instructions › Statutory position — the meaning of 'scrap' in the Explanation to s.206C, and the s.206C(1) table as it stands from 1 April 2025
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Statutory position — the meaning of 'scrap' in the Explanation to s.206C, and the s.206C(1) table as it stands from 1 April 2025

The Assessing Officer says everything I sold as waste was 'scrap' and wants one per cent. What does the Act actually define as scrap, and what else is in the s.206C(1) table now?

The Assessing Officer says everything I sold as waste was 'scrap' and wants one per cent. What does the Act actually define as scrap, and what else is in the s.206C(1) table now?

Explanation clause (b) to s.206C defines 'scrap' as 'waste and scrap from the manufacture or mechanical working of materials which is definitely not usable as such because of breakage, cutting up, wear and other reasons'. The definition has two limbs that must both be satisfied — an origin limb (waste and scrap from the manufacture or mechanical working of materials) and a condition limb (definitely not usable as such) — and it is the second limb that decides most disputes, because material which the buyer takes and uses as raw material is on its face usable as such.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2025-04-01, reported as Income-tax Act, 1961, s.206C(1) and Explanation, as they stand from 1 April 2025. It bears on section 206C, section 206C(1), section 206C(1A), section 288(2), section 10(20) of the Income Tax Act 1961, in TDS Defaults, How Tax Law Is Read and Evidence & Burden of Proof matters.

Still good law. The definition of 'scrap' in Explanation (b) has stood unchanged through every amendment traced on these pages. The table entries are as printed on two departmental pages stamped Year 2025 and Year 2026 which agree word for word. No Finance Act text was retrieved this pass. Anything applying a two and one-half per cent rate to forest produce for a period on or after 1 April 2025 is superseded by amendment.

Why it matters

The word is the most litigated in the section, and the two limbs pull in opposite directions. On the origin limb the Revenue has the better of it: nothing in Explanation (b) or in Explanation (c), which defines "seller", requires the seller to be a manufacturer or to have generated the scrap himself. Two Tribunals have said so in their own words: the Jaipur Bench in Ramdas Trading Company recorded that the contrary contentions are "squarely covered against the assessee by the decision of Special Bench of Tribunal in the case of Bharti Auto Products Vs. CIT-II", and the Ahmedabad Bench in Umeshkumar Harilal Shah held on the CBDT circular before it that "there is no requirement that the goods to be eligible for scrap should be produced/manufacture by the seller itself". The Special Bench decision itself was not retrieved on this build and nothing is stated here as its own reasoning. On the condition limb the taxpayer has the better of it: cotton waste reused as raw material by another spinner, rags and wipers cut to order, and ship-breaking material that is usable as such have all been held outside the definition. Practitioners should also know what changed in the table on 1 April 2025. Serial (v), 'Any other forest produce not being timber or tendu leaves — Two and one-half per cent', was omitted by Act No. 7 of 2025 with effect from 1 April 2025, and the words 'or any other forest produce (not being tendu leaves)' were inserted into serial (iii), so that forest produce obtained under a forest lease now sits at two per cent alongside timber rather than at two and one-half per cent under a separate entry. The same Act on the same date also cut the rate in serials (iii) and (iv) from two and one-half per cent to two per cent, so from 1 April 2025 every timber and forest-produce entry in the table stands at two per cent and the two and one-half per cent rate has disappeared from the table altogether.

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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