VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.92CE(2A) to (2D): the one-time option to pay eighteen per cent additional income-tax instead of repatriating, and the three doors it closes — no deduction, no credit, no refund
CBDT Circulars & InstructionsCuts both wayss.92CEs.92CE(2)s.92CE(2A)s.92CE(2B)s.92CE(2C)s.92CE(2D)Rule 10CB

Statutory position — s.92CE(2A) to (2D): the one-time option to pay eighteen per cent additional income-tax instead of repatriating, and the three doors it closes — no deduction, no credit, no refund

My associated enterprise will not send the money back. Can I simply pay tax on it and be done, and if I do, what do I give up?

My associated enterprise will not send the money back. Can I simply pay tax on it and be done, and if I do, what do I give up?

Yes. Section 92CE(2A) gives the assessee an option, "without prejudice to the provisions of sub-section (2)", where the excess money or part of it has not been repatriated within the prescribed time, to "pay additional income-tax at the rate of eighteen per cent on such excess money or part thereof". The price of that option is stated in the next three sub-sections and it is absolute. Sub-section (2B) makes the payment "the final payment of tax in respect of the excess money or part thereof not repatriated" and provides that "no further credit therefor shall be claimed by the assessee or by any other person in respect of the amount of tax so paid". Sub-section (2C) provides that "No deduction under any other provision of this Act shall be allowed to the assessee in respect of the amount on which tax has been paid in accordance with the provisions of sub-section (2A)". Sub-section (2D) then closes the loop in the taxpayer's favour: once the additional income-tax is paid "he shall not be required to make secondary adjustment under sub-section (1) and compute interest under sub-section (2) from the date of payment of such tax". These four sub-sections were inserted by Act No. 23 of 2019 with effect from 1 September 2019.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2019-09-01, reported as Section 92CE(2A) to (2D) of the Income-tax Act, 1961, transcribed from incometaxindia.gov.in/w/section-92ce-3 (heading "Secondary adjustment in certain cases", Year: 2021) and read again word for word on incometaxindia.gov.in/w/section-92ce-2 (Year: 2019 (No. 2)); footnote 20 on the Year 2021 page: "Ins. by the Act. No. 23 of 2019, w.e.f. 1-9-2019.". It bears on section 92CE, section 92CE(2), section 92CE(2A), section 92CE(2B), section 92CE(2C), section 92CE(2D), section Rule 10CB of the Income Tax Act 1961, in Assessment & Scrutiny and How Tax Law Is Read matters.

Still good law. The text is current so far as I could establish: two departmental pages with different "Year:" stamps (2019 (No. 2) and 2021) print the four sub-sections identically, and the Year 2021 page carries a footnote dating their insertion to Act No. 23 of 2019 with effect from 1 September 2019. The sub-sections were read again on incometaxindia.gov.in/w/section-92ce-6 (Year: 2024 (No. 1)), the latest page located, and came back in identical words; no suffix above -6 was probed. I found no decision construing s.92CE(2A) and did not check judicial treatment of these sub-sections.

Why it matters

The option is usually the commercially sensible answer where the associated enterprise is a foreign parent that will not repatriate, because the alternative is a deemed advance carrying imputed interest under Rule 10CB for as long as the money stays abroad — indefinitely. But the reader must understand three limits before he takes it. First, the tax is on the EXCESS MONEY itself, not on the interest, and eighteen per cent of the whole unrepatriated amount can dwarf a year or two of imputed interest, so the option is worth taking only when repatriation is genuinely not going to happen. The eighteen per cent in the section is not the whole cost. Section 2(4) of the Finance (No. 2) Act, 2019 increases the tax charged under s.92CE(2A) by a surcharge of twelve per cent, and s.2(12) of that Act adds a four per cent Health and Education Cess on the tax and surcharge together, so the effective rate for that year is 20.9664 per cent. Because the surcharge and cess come from the annual Finance Act and not from s.92CE, the rate has to be taken from the Finance Act in force for the year in which the option is exercised. Second, the finality is complete: it is not an advance payment of anything, no credit can be taken by the assessee or by any other person — which means the associated enterprise cannot claim it either — and no deduction is allowed anywhere else in the Act for the amount taxed. Third, sub-section (2D) stops the interest only FROM THE DATE OF PAYMENT. Interest under sub-section (2) read with Rule 10CB continues to run up to that date, so the interest for the period between the end of the repatriation window and the date the additional tax is paid still has to be computed and offered.

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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Related

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