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Case lawCBDT Circulars & Instructions › Statutory position — s.10(10AA): the four-limb leave encashment computation, the thirty-days-a-year cap in the Explanation, and the Rs. 25,00,000 limit notified by S.O. 2276(E) from 1 April 2023
CBDT Circulars & InstructionsCuts both wayss.10(10AA)s.10(10AA)(i)s.10(10AA)(ii)s.10(10)

Statutory position — s.10(10AA): the four-limb leave encashment computation, the thirty-days-a-year cap in the Explanation, and the Rs. 25,00,000 limit notified by S.O. 2276(E) from 1 April 2023

My client is a private-sector retiree who was paid leave encashment. The Assessing Officer has restricted the exemption to three lakhs. What is the current limit, what instrument set it, and how is the exempt amount actually computed?

My client is a private-sector retiree who was paid leave encashment. The Assessing Officer has restricted the exemption to three lakhs. What is the current limit, what instrument set it, and how is the exempt amount actually computed?

The current limit for a non-government employee is Rs. 25,00,000, specified by Notification No. 31/2023, S.O. 2276(E), which is deemed to have come into force with effect from 1 April 2023, in relation to employees mentioned in s.10(10AA)(ii) who retire, whether on superannuation or otherwise. The exempt amount is the least of four figures — the amount actually received; the cash equivalent of the earned leave at credit, the entitlement to earned leave being capped by the Explanation at thirty days for every year of actual service rendered to the employer from whose service he has retired; ten months' average salary computed on the average salary drawn during the ten months immediately preceding retirement; and the notified limit — and the notified limit is an aggregate across employers in the same year and across earlier years.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2023-04-01, reported as Income-tax Act, 1961, s.10(10AA), as printed on the departmental Year 2025 and Year 2018 pages; Notification No. 31/2023/F. No. 200/3/2023-ITA-I, S.O. 2276(E). It bears on section 10(10AA), section 10(10AA)(i), section 10(10AA)(ii), section 10(10) of the Income Tax Act 1961, in Salary & Perquisites and Capital Gains Exemptions matters.

Still good law. Two departmental editions seven years apart print clause (10AA) identically, and the Department's current explanatory page, amended on its face up to the Finance Act 2026, still prints Rs. 25,00,000 and the same four-limb computation, which is the best evidence obtainable here that both the clause and the figure hold for tax years up to AY 2026-27. No Finance Act text was retrieved and no amendment footnote against clause (10AA) could be read, so the clause's legislative history is not established. Whether the Rs. 25,00,000 limit reaches employees who retired before 1 April 2023 is contested and is dealt with in the Tribunal entries this library already holds; nothing in this entry decides it.

Why it matters

This is the figure a reader will copy straight into a computation, so both halves of it matter — the number and the date. The number moved from Rs. 3,00,000 to Rs. 25,00,000, and the notification does it not by a plain prospective commencement but by the words "shall be deemed to have come into force with effect from the 1st day of April, 2023", which is why the retrospectivity question for earlier retirees has been litigated; this library already holds the Tribunal decisions on that, including Awadhesh Kumar Dixit v DCIT. What is often missed is everything around the number. First, the limb split: an employee of the Central Government or a State Government is inside sub-clause (i) and his leave encashment on retirement is exempt without any ceiling, while everyone else is inside sub-clause (ii) and subject to all four limbs — and who counts as a Government employee for this purpose is itself the question the Delhi High Court decided in Kamal Kumar Kalia v Union of India, already in this library. Second, the thirty-day cap in the Explanation is a cap on ENTITLEMENT, computed per year of actual service with the employer from whose service he has retired; an employer's more generous leave rules do not enlarge the exemption. Third, the ten-month test is a ten-month AVERAGE of salary drawn in the ten months immediately preceding retirement, not the last month annualised. Fourth, "salary" for this clause is fixed by the Explanation to s.10(10) as the meaning in clause (h) of rule 2 of Part A of the Fourth Schedule, which is what the Madras High Court decided in K. Gopalakrishnan v Central Board of Direct Taxes. Fifth, both provisos are aggregation provisions and work exactly as those to s.10(10) do — one limit across employers in the same previous year, reduced in later years by whatever was already left out of total income under the sub-clause.

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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