VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.10(10): the three limbs of the gratuity exemption, the twenty-lakh ceiling set by S.O. 1213(E), and why the ceiling is an aggregate across employers and across years
CBDT Circulars & InstructionsCuts both wayss.10(10)s.10(10)(i)s.10(10)(ii)s.10(10)(iii)s.10(10AA)s.17(3)

Statutory position — s.10(10): the three limbs of the gratuity exemption, the twenty-lakh ceiling set by S.O. 1213(E), and why the ceiling is an aggregate across employers and across years

My client retired last year and received gratuity from two employers in the same year. The Assessing Officer says he can only have one twenty-lakh exemption in total, and has also asked about gratuity he received when he changed jobs in 2014. Is that right, and where does the twenty-lakh figure come from?

My client retired last year and received gratuity from two employers in the same year. The Assessing Officer says he can only have one twenty-lakh exemption in total, and has also asked about gratuity he received when he changed jobs in 2014. Is that right, and where does the twenty-lakh figure come from?

The Assessing Officer is right on both points. Section 10(10) has three separate limbs and only the third carries a Central Government ceiling; that ceiling is twenty lakh rupees, specified by CBDT notification S.O. 1213(E) dated 8 March 2019 in relation to employees who retire, become incapacitated prior to retirement or die on or after 29 March 2018, or whose employment is terminated on or after that date. The first proviso to the clause caps the aggregate exemption where gratuities are received from more than one employer in the same previous year, and the second proviso reduces the ceiling by whatever was left out of total income under the clause in any earlier previous year — so the twenty lakhs is a once-in-a-lifetime cumulative allowance, not a per-employer or per-year one.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2018-03-29, reported as Income-tax Act, 1961, s.10(10), as printed on the departmental Year 2025, Year 2019 (No. 1) and Year 2018 pages; CBDT notification S.O. 1213(E) dated 8 March 2019. It bears on section 10(10), section 10(10)(i), section 10(10)(ii), section 10(10)(iii), section 10(10AA), section 17(3) of the Income Tax Act 1961, in Salary & Perquisites and Capital Gains Exemptions matters.

Still good law. Three departmental editions (Year 2018, Year 2019 (No. 1) and Year 2025) print clause (10) in identical words, and the Department's current explanatory page, which states on its face that it is amended up to the Finance Act 2026, still prints Rs. 20,00,000 as the limb (iii) figure. That is the best evidence obtainable on this pass that both the clause and the figure are unchanged for tax years up to AY 2026-27. It is not the same as reading a Finance Act: no Finance Act text was retrieved this pass, and neither departmental page carried an amendment footnote against clause (10), so the clause's own legislative history has not been established here. I did not carry out any check of judicial treatment of s.10(10) beyond reading G. Srinivasan v Union of India.

Why it matters

This is the single most-received retirement payment in Indian practice and the clause is more structured than it looks. Limb (i) covers death-cum-retirement gratuity under the Central Government's revised Pension Rules or the CCS (Pension) Rules 1972, similar schemes for the civil services of the Union or a State, holders of civil posts, all-India services, employees of a local authority, and retiring gratuity under the Pension Code applicable to the defence services: that limb is unqualified and carries no monetary ceiling at all. Limb (ii) covers gratuity received under the Payment of Gratuity Act 1972 and exempts it to the extent of the amount calculated under sub-sections (2) and (3) of section 4 of that Act — so the ceiling for a covered employee is imported from the labour statute, not from any income-tax notification, and it moved to twenty lakh rupees only on 29 March 2018 by S.O. 1420(E), the Payment of Gratuity (Amendment) Act 2018 having been brought into force that day by S.O. 1419(E). Limb (iii) is the residual limb — any other gratuity on retirement, incapacity, termination or death — and exempts one-half month's salary for each year of completed service computed on the average salary of the ten months immediately preceding the month of the event, subject to the Central Government's notified limit. It is only limb (iii) that S.O. 1213(E) speaks to. Two consequences follow that practitioners miss. First, a covered employee arguing under limb (ii) is arguing about section 4(3) of the Payment of Gratuity Act, and the income-tax notification does not help him. Second, both provisos to the clause are aggregation provisions and they operate across employers within a year and across years — so a client who took a tax-free gratuity on an earlier job change has already spent part of his allowance, and the return position has to be built from his whole career, not from this year's Form 16. The Explanation fixes "salary" for both this clause and s.10(10AA) as the meaning in clause (h) of rule 2 of Part A of the Fourth Schedule, which is the point the Madras High Court decided in K. Gopalakrishnan v Central Board of Direct Taxes, already in this library.

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