VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.46(1) and s.46(2): the company is not charged on a liquidation distribution, the shareholder is, and the s.2(22)(c) deemed dividend is deducted before capital gains are computed
CBDT Circulars & InstructionsCuts both wayss.46s.46(1)s.46(2)s.45s.2(22)(c)s.48s.55(2)(b)(iii)s.2(17)

Statutory position — s.46(1) and s.46(2): the company is not charged on a liquidation distribution, the shareholder is, and the s.2(22)(c) deemed dividend is deducted before capital gains are computed

My client's company has gone into liquidation and the liquidator has distributed cash and one immovable property to the shareholders. Who is charged to capital gains — the company or the shareholder — and what exactly is the figure the shareholder is taxed on?

My client's company has gone into liquidation and the liquidator has distributed cash and one immovable property to the shareholders. Who is charged to capital gains — the company or the shareholder — and what exactly is the figure the shareholder is taxed on?

Neither limb of section 46 concerns a buy-back, so the 1 October 2024 buy-back changeover does not touch it; section 46 governs liquidation only, and it has read in identical words on departmental pages stamped Year 1966, Year 1973, Year 2009 and Year 2024 (No. 2). Section 46(1) says that where the assets of a company are distributed to its shareholders on its liquidation, that distribution "shall not be regarded as a transfer by the company for the purposes of section 45" — so the company is not charged on the distribution. Section 46(2) then charges the shareholder: he is chargeable under the head "Capital gains" on the money received plus the market value of the other assets on the date of distribution, "as reduced by the amount assessed as dividend within the meaning of sub-clause (c) of clause (22) of section 2", and the sum so arrived at is deemed to be the full value of the consideration for section 48.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text), reported as Section 46 of the Income-tax Act, 1961, transcribed from incometaxindia.gov.in/w/section-46-63 (heading "Capital gains on distribution of assets by companies in liquidation", Year: 2024 (No. 2)) and read again in identical words on /w/section-46 (Year: 2009), /w/section-46-26 (Year: 1973) and /w/section-46-50 (Year: 1966); the same words are reproduced by the Supreme Court in Vijay Kumar Budhia v. CIT (14 September 1993). It bears on section 46, section 46(1), section 46(2), section 45, section 2(22)(c), section 48, section 55(2)(b)(iii), section 2(17) of the Income Tax Act 1961, in Capital Gains and How Tax Law Is Read matters.

Still good law. The text is current and stable: four departmental pages carrying different "Year:" stamps (1966, 1973, 2009 and 2024 (No. 2)) print sub-sections (1) and (2) identically, and the Supreme Court set the same words out in 1993. I probed suffixes -26, -50 and -63 and the bare page only; a still later departmental version cannot be excluded, though the 2024 (No. 2) stamp is the latest available on this route. I did not trace judicial treatment of s.46 beyond the two Supreme Court decisions named above, and I did not check whether any High Court has construed the phrase "market value of the other assets on the date of distribution".

Why it matters

The deduction is the part that is got wrong, and it is got wrong in both directions. It is not a deduction of the whole distribution, and it is not a deduction of the accumulated profits as such: it is a deduction of the amount ASSESSED as dividend within s.2(22)(c) — that is, the part of the distribution attributable to accumulated profits immediately before liquidation, which is charged separately as dividend income. Deduct it twice, or fail to deduct it at all, and the capital gains figure is wrong. Then note what s.46(2) does NOT do: the only deduction it expressly provides is the s.2(22)(c) dividend. Everything else — cost of acquisition, indexation, expenditure on the transfer — comes in afterwards, because the sub-section directs that the resulting sum is the FULL VALUE OF THE CONSIDERATION for s.48, and it is s.48 that then allows cost and improvement. Practitioners who treat the s.46(2) figure as the capital gain itself overstate the charge by the whole cost of the shares. Two further limits matter. First, the asset side is valued at "the market value of the other assets on the date of distribution" — not the book value in the liquidator's account, and not the value on the date the shares were extinguished. Second, when the shareholder later sells the asset he received, s.55(2)(b)(iii) gives him a cost of acquisition equal to "the fair market value of the asset on the date of distribution", but only "where the assessee has been assessed to income-tax under the head 'Capital gains' in respect of that asset under section 46" — so the step-up depends on the s.46(2) charge actually having been made. Finally, s.46(1) protects the company from a s.45 charge on the DISTRIBUTION; it says nothing about the sale of assets by the liquidator to a third party, which is an ordinary transfer by the company and is chargeable in the usual way.

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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