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Case lawCBDT Circulars & Instructions › Statutory position — s.40(a)(ib): the whole payment is disallowed where equalisation levy was deductible on it and was not deducted or not paid by the s.139(1) due date, and the proviso that gives it back
CBDT Circulars & InstructionsCuts both wayss.40(a)(ib)s.40(a)(ia)s.139(1)s.165s.165(2)s.165As.166s.166As.170s.171

Statutory position — s.40(a)(ib): the whole payment is disallowed where equalisation levy was deductible on it and was not deducted or not paid by the s.139(1) due date, and the proviso that gives it back

The Assessing Officer has disallowed the entire online advertising spend because equalisation levy was not deducted. Is that right, and can the deduction be recovered in a later year?

The Assessing Officer has disallowed the entire online advertising spend because equalisation levy was not deducted. Is that right, and can the deduction be recovered in a later year?

It is right in principle, and the disallowance is of the whole consideration, not of the six per cent. Section 40(a)(ib) of the Income-tax Act disallows 'any consideration paid or payable to a non-resident for a specified service on which equalisation levy is deductible under the provisions of Chapter VIII of the Finance Act, 2016, and such levy has not been deducted or after deduction, has not been paid on or before the due date specified in sub-section (1) of section 139'. Note where the levy itself lives: Chapter VIII of the Finance Act, 2016, not the Income-tax Act. The proviso restores the deduction — 'where in respect of any such consideration, the equalisation levy has been deducted in any subsequent year or has been deducted during the previous year but paid after the due date specified in sub-section (1) of section 139, such sum shall be allowed as a deduction in computing the income of the previous year in which such levy has been paid'.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text), reported as Section 40(a)(ib) of the Income-tax Act, 1961, with its proviso, transcribed from incometaxindia.gov.in/w/section-40-64 (heading 'Amounts not deductible', Year: 2025), read once as part of a continuous run of sub-clauses (ia), (ib) and (ic) and once again on a second fetch asking for sub-clause (ib) together with every proviso to it. It bears on section 40(a)(ib), section 40(a)(ia), section 139(1), section 165, section 165(2), section 165A, section 166, section 166A, section 170, section 171 of the Income Tax Act 1961, in Deductions & Disallowances and How Tax Law Is Read matters.

Still good law. The text is from a departmental page stamped Year 2025, which is the most recent version of section 40 I located, and the sub-clause and its proviso were transcribed twice from that page on differently worded requests, the second asking expressly for every proviso to sub-clause (ib), with the same result. The clause remains on the statute book. It matters for assessment years in which the six per cent levy was chargeable, that is, up to and including consideration received or receivable before 1 April 2025. What I did not do: I could not read the amendment footnote for sub-clause (ib) and so cannot state when it was inserted, and I did not search for any decision construing it — I found none in the course of this work, but I did not run a search directed at that question, so that is not a finding that none exists.

Why it matters

Three things about the drafting decide cases. First, the clause bites on consideration 'on which equalisation levy is DEDUCTIBLE'. Only the six per cent levy on specified services under section 165 is deducted — the two per cent levy on e-commerce supply or services under section 165A is paid by the non-resident operator itself under section 166A, and nothing is deductible on it. So section 40(a)(ib) has no application to an e-commerce supply, and a disallowance premised on the two per cent levy is premised on the wrong provision. Second, if the levy was not deductible at all — because the section 165(2) exclusions applied, most commonly because the aggregate consideration from that non-resident in the previous year did not exceed one lakh rupees, or because the payment was not for the purposes of business or profession — then the condition in the clause is not satisfied and there is nothing to disallow. That is the first line of defence and it is a pure question of applying section 165(2). Third, unlike section 40(a)(ia), which restricts the disallowance to thirty per cent of the sum, section 40(a)(ib) carries no percentage: the whole consideration goes. The proviso is a deferral, not a forfeiture — the deduction comes back in the year the levy is actually paid, so the practical exposure of a late payer is a timing loss and the interest and penalty exposure under sections 170 and 171 of the Finance Act 2016, not a permanent disallowance.

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Related

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