VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — Rule 10CB: the five different starting points for the ninety-day repatriation clock, and the two SEPARATE interest rate bases — SBI one-year MCLR plus 325 basis points for a rupee transaction, six-month LIBOR plus 300 basis points for a foreign-currency one
CBDT Circulars & InstructionsCuts both waysValidity unconfirmeds.92CEs.92CE(2)s.139(1)s.92CCs.92CBs.90s.90As.92BRule 10CBRule 44HRule 26

Statutory position — Rule 10CB: the five different starting points for the ninety-day repatriation clock, and the two SEPARATE interest rate bases — SBI one-year MCLR plus 325 basis points for a rupee transaction, six-month LIBOR plus 300 basis points for a foreign-currency one

My primary adjustment stands and the money is still with my overseas associated enterprise. When exactly do my ninety days start, and at what rate is the deemed advance to be charged interest?

My primary adjustment stands and the money is still with my overseas associated enterprise. When exactly do my ninety days start, and at what rate is the deemed advance to be charged interest?

Rule 10CB(1) gives the repatriation window as "on or before ninety days" from a starting point that differs with the source of the primary adjustment: from the s.139(1) due date where the adjustment was made suo motu in the return; from the date of the order of the Assessing Officer or the appellate authority where the adjustment in that order was accepted; where the adjustment is determined by an APA, from the date of filing the s.139(1) return if the APA was entered into on or before the due date, and from the END OF THE MONTH in which the APA was entered into if it came later; from the s.139(1) due date where the safe harbour option was exercised; and from the date the Assessing Officer gives effect under rule 44H to a mutual agreement procedure resolution. Rule 10CB(2) then fixes two different rate bases, and they are not interchangeable: for a transaction denominated in INDIAN RUPEES the imputed per annum interest is "at the one year marginal cost of fund lending rate of State Bank of India as on 1st of April of the relevant previous year plus three hundred twenty five basis points"; for a transaction denominated in FOREIGN CURRENCY it is "at six month London Interbank Offered Rate as on 30th September of the relevant previous year plus three hundred basis points". Clause (ii) still names LIBOR. LIBOR settings have been permanently discontinued and no replacement benchmark has been substituted into this rule, so for recent previous years the foreign-currency limb prescribes a rate that may not exist for 30 September of the relevant year.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2017-06-15, reported as Rule 10CB of the Income-tax Rules, 1962, transcribed in full from incometaxindia.gov.in/w/rule-10cb (Income-tax Rules, 1962; heading "Computation of interest income pursuant to secondary adjustments"; no "Year:" stamp), with the footnotes transcribed verbatim on a second fetch of the same page. It bears on section 92CE, section 92CE(2), section 139(1), section 92CC, section 92CB, section 90, section 90A, section 92B, section Rule 10CB, section Rule 44H, section Rule 26 of the Income Tax Act 1961, in Assessment & Scrutiny and How Tax Law Is Read matters.

Validity check could not be completed. Validity check could not be completed. The rule text is verified — it was transcribed twice from the departmental page, and the distinctive phrase "three hundred twenty five basis points" was independently located on indiankanoon's page for rule 10CB — but departmental rule pages carry no "Year:" stamp, so I cannot confirm from the page that no later amendment exists beyond the IT (Eleventh Amdt.) Rules, 2019 recorded in its footnotes. I did not check judicial treatment of the rule beyond the ITAT Mumbai order of 14 February 2025 noted in this entry.

Why it matters

Two things go wrong in practice. The first is the starting point. Practitioners assume the clock always runs from the return due date; it does not. Where the adjustment was made by the officer and accepted, it runs from the date of the ORDER, which can be much earlier than the next return due date; where an APA is signed after the return due date, it runs from the END OF THE MONTH of signature. Rule 10CB(3) then separately fixes the date from which interest is CHARGEABLE, matching the same four starting points, so the ninety-day window is not itself interest-free time added on — the interest under sub-rule (3) runs from the sub-rule (1) starting point. The second is the rate. Using the MCLR base on a dollar-denominated receivable, or LIBOR on a rupee one, produces a number the Revenue will not accept and a number that is often materially different: the two bases are drawn on different dates (1 April versus 30 September of the relevant previous year) and carry different spreads (325 versus 300 basis points). AND THE FOREIGN-CURRENCY BASE IS A DEAD RATE. Rule 10CB(2)(ii) has not been amended: the departmental rule page still prints "six month London Interbank Offered Rate as on 30th September of the relevant previous year", and I found no notification substituting another benchmark. LIBOR settings have ceased, so for a previous year in which no six-month LIBOR setting exists on 30 September the rule names a rate that cannot be read. That is a gap in the rule, not a licence to substitute SOFR or any other benchmark of your own; the entry states the rule as it stands and the reader should put the difficulty on record rather than pick a rate. Note that the currency test is the currency in which the INTERNATIONAL TRANSACTION is denominated, not the currency in which the money happens to be held; and the Explanation supplies the conversion rule — the telegraphic transfer buying rate on the last day of the previous year in which the transaction was undertaken, with "telegraphic transfer buying rate" carrying the meaning given in the Explanation to rule 26.

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