VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — rule 12CA and rule 12CB with s.115UA(4) and s.115UB(7): the two pass-through statements, Forms 64A to 64D, and the 15 June and 30 June dates
CBDT Circulars & InstructionsCuts both waysValidity unconfirmeds.115UA(4)s.115UB(7)s.115UAs.115UBRule 12CARule 12CBs.10(23FC)s.10(23FCA)s.10(23FD)s.10(23FBA)s.10(23FBB)

Statutory position — rule 12CA and rule 12CB with s.115UA(4) and s.115UB(7): the two pass-through statements, Forms 64A to 64D, and the 15 June and 30 June dates

Our REIT has to give unit holders a statement of distributed income and file one with the department. Which form goes where, by when, and is the machinery the same for an Alternative Investment Fund?

Our REIT has to give unit holders a statement of distributed income and file one with the department. Which form goes where, by when, and is the machinery the same for an Alternative Investment Fund?

There are two parallel sets and they are not interchangeable. For a business trust, section 115UA(4) requires the person responsible for paying the distributed income to furnish a statement to the unit holder and to the prescribed authority, and rule 12CA prescribes it: Form No. 64A, verified by an accountant and filed electronically under digital signature with the Principal Commissioner or Commissioner within whose jurisdiction the principal office of the business trust is situated, by 15 June of the financial year following the previous year in which the income is distributed; and Form No. 64B to the unit holder by 30 June of that financial year, generated and downloaded from the departmental web portal. For an investment fund, section 115UB(7) requires the same thing and rule 12CB prescribes Form No. 64C to the unit holder by 30 June and Form No. 64D to the Principal Commissioner or Commissioner by 15 June, on the same electronic footing.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text), reported as Rule 12CA as printed on incometaxindia.gov.in/w/rule-12ca and rule 12CB on incometaxindia.gov.in/w/rule-12cb, neither page carrying a Year stamp; section 115UA(4) on incometaxindia.gov.in/w/section-115ua-10 (Year 2024 No. 2); section 115UB(7) on incometaxindia.gov.in/w/section-115ub (Year 2026). It bears on section 115UA(4), section 115UB(7), section 115UA, section 115UB, section Rule 12CA, section Rule 12CB, section 10(23FC), section 10(23FCA), section 10(23FD), section 10(23FBA), section 10(23FBB) of the Income Tax Act 1961, in Charitable Trusts & Exemption, TDS Defaults and Assessment & Scrutiny matters.

Validity check could not be completed. Validity check could not be completed. Departmental rule pages carry no Year stamp, so neither rule could be dated the way a section can, and the substitution notes printed on the two pages were not corroborated on a second route. The two statutory hooks, section 115UA(4) and section 115UB(7), were each read on a year-stamped departmental page (Year 2024 No. 2 and Year 2026 respectively). No judicial treatment was searched for, and no penalty provision for failure to furnish these statements was established on this pass — sections 271FAA and 271FAB were both read on departmental pages and neither is that provision.

Why it matters

These statements are not paperwork; they are the documents the unit holder's return is built from, and they are where the whole substantive analysis has to be reduced to figures. A Form 64B that does not separate the sub-clause (a) interest component, the clause (23FCA) direct-rent component and the sub-clause (b) special purpose vehicle dividend component makes it impossible for the unit holder to apply section 10(23FD) correctly, because the dividend component is exempt to him only where the special purpose vehicle has NOT exercised the option under section 115BAA. The same is true of a Form 64C that does not separate the business-income proportion, which is exempt in the investor's hands under section 10(23FBB) because the fund has been charged on it under section 10(23FBA). Two practical points on the mechanics. First, the two forms in each pair go to different recipients on different dates and by different routes — the departmental copy is filed by the payer under digital signature, while the unit holder's copy is generated and downloaded from the web portal specified by the Principal Director General or Director General of Income-tax (Systems) and verified by the payer. A statement typed up by the fund and emailed out is not the prescribed form. Second, both rules place the obligation on "the person responsible for" paying or crediting the income — and rule 12CB puts it on that person AND on the investment fund, so a manager cannot discharge the fund's own obligation by pointing at the trustee, or the reverse.

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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