VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — Rule 10U: the exclusions a cross-border case must clear first — the Foreign Institutional Investor and offshore-derivative carve-outs, and how the three crore rupee tax benefit is actually computed
CBDT Circulars & InstructionsCuts both waysRule 10URule 10U(1)Rule 10U(2)Rule 10U(3)s.95s.96s.102s.102(6)s.102(10)s.90s.90As.115AD

Statutory position — Rule 10U: the exclusions a cross-border case must clear first — the Foreign Institutional Investor and offshore-derivative carve-outs, and how the three crore rupee tax benefit is actually computed

Before I argue the merits of a GAAR notice for a foreign investor, which exclusions in Rule 10U do I have to run, and how is the three crore rupee tax benefit figure arrived at?

Before I argue the merits of a GAAR notice for a foreign investor, which exclusions in Rule 10U do I have to run, and how is the three crore rupee tax benefit figure arrived at?

Rule 10U(1) takes four classes of case outside Chapter X-A altogether. Clause (a) is the monetary floor: the Chapter does not apply to an arrangement where the tax benefit in the relevant assessment year arising "in aggregate, to all the parties to the arrangement" does not exceed three crore rupees. Clause (b) excludes a Foreign Institutional Investor that is an assessee under the Act, that "has not taken benefit of an agreement referred to in section 90 or section 90A", and that has invested in listed or unlisted securities in accordance with the SEBI (Foreign Institutional Investors) Regulations, 1995. Clause (c) excludes a non-resident in relation to an investment made by him "by way of offshore derivative instruments or otherwise, directly or indirectly, in a Foreign Institutional Investor". Clause (d) grandfathers income from the transfer of investments made before 1 April 2017. Rule 10U(3)(iv) then tells you how to quantify the tax benefit for the clause (a) threshold: for sub-clauses (a) to (e) of s.102(10) it is "the amount of tax", and for sub-clause (f), an increase in loss, it is "the tax that would have been chargeable had the increase in loss referred to therein been the total income".

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2018-04-01, reported as Rule 10U of the Income-tax Rules, 1962 (heading "Chapter X-A not to apply in certain cases"), transcribed from incometaxindia.gov.in/w/rule-10u, which carries no "Year:" stamp but does carry dated amendment footnotes 54 and 55; sub-rules (1)(a), (1)(b), (1)(c) and (3)(iv) corroborated against the text of the rule reproduced in The Authority for Advance Rulings (Income Tax) and others v Tiger Global International II Holdings, 2026 INSC 60 (Supreme Court, 15 January 2026), at and around paragraphs 12.29 and 12.30. It bears on section Rule 10U, section Rule 10U(1), section Rule 10U(2), section Rule 10U(3), section 95, section 96, section 102, section 102(6), section 102(10), section 90, section 90A, section 115AD of the Income Tax Act 1961, in How Tax Law Is Read, Assessment & Scrutiny, Capital Gains and Residence & Treaty Benefit matters.

Still good law. The text set out here is the current text, and it can now be dated. The departmental page carries no "Year:" stamp but does carry numbered amendment footnotes: footnote 54, against clause (1)(d), and footnote 55, against sub-rule (2), each read "Substituted by the IT (Tenth Amdt.) Rules, 2026, w.e.f. 31-3-2026", and each set out the immediately preceding text "as amended by the IT (Sixteenth Amdt.) Rules, 2016, w.e.f. 22-6-2016". That footnote is corroborated on an independent route: the Supreme Court, in a judgment delivered on 15 January 2026, reproduces sub-rule (2) in exactly the pre-substitution words the footnote records. The practical consequence is important — for every assessment year governed by the Income-tax Act, 1961 it is the EARLIER text of sub-rule (2) and clause (1)(d) that applies, and the version set out in the facts took effect only on 31 March 2026. Sub-rules (1)(a), (1)(b), (1)(c) and (3)(iv) carry no amendment footnote and were read in identical terms in the Supreme Court's reproduction, so they stand as originally made. No check of judicial treatment beyond that judgment was made.

Why it matters

Rule 10U(1)(b) contains a trap that decides FII cases: the exclusion is available only to an FII that has NOT taken the benefit of a treaty. An FII that has claimed treaty relief has, by that act, stepped outside the carve-out and into Chapter X-A, where s.90(2A) then denies it the treaty override. That is a coherent scheme and it should be understood as a choice rather than an accident. Clause (c) is the companion: the participatory-note holder investing through an FII is excluded in relation to that investment, whether the route is an offshore derivative instrument "or otherwise", and whether the investment is direct or indirect. On the threshold, three points matter. First, the figure is a tax benefit, not a transaction value, and it is aggregated across ALL the parties to the arrangement for the relevant assessment year, so a structure that produces a small benefit for your client may still be inside the Chapter once the other parties are added in. Second, "party" is defined in s.102(6) to include a permanent establishment, which widens the aggregation. Third, the loss limb is the one people get wrong: an arrangement producing no tax saving at all but an increased loss is valued by notionally treating the increase in loss as total income and computing the tax on it. On grandfathering, Rule 10U(2) is the sting in the tail — it applies the Chapter "to any arrangement, irrespective of the date on which it has been entered into, in respect of the tax benefit obtained from the arrangement on or after the 1st day of April, 2017", carving out only income from the transfer of investments made before that date. An old structure is not immune; only pre-1 April 2017 investments, and only as to income from their transfer, are protected. Read the version that governs your year. The words of sub-rule (2) set out above are the sub-rule as substituted with effect from 31 March 2026; for every assessment year under the Income-tax Act, 1961 the sub-rule opened "Without prejudice to the provisions of clause (d) of sub-rule (1)" and contained no exception of its own, the carve-out for pre-1 April 2017 investments living in clause (1)(d) alone. The result is the same in substance, but if you are quoting the sub-rule in a reply to a notice, quote the text that was in force in the year.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

Not yet CA-verified. This entry was found through the sources listed under the Sources tab, and the summary reflects what those sources say. Nobody has yet read the full judgment and signed it off. Check the source before relying on it.

Read aloud by your device. Press again to stop.

Related

Other authorities on the same sections.