VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.10(11) and s.10(12) with Rule 9D: interest on the employee's own provident fund contribution above the annual threshold, why there are TWO thresholds, and the two-account mechanism from previous year 2021-22
CBDT Circulars & InstructionsCuts both wayss.10(11)s.10(12)Rule 9Ds.17(2)(vii)

Statutory position — s.10(11) and s.10(12) with Rule 9D: interest on the employee's own provident fund contribution above the annual threshold, why there are TWO thresholds, and the two-account mechanism from previous year 2021-22

My client's EPF interest certificate now shows a taxable interest figure and the return utility is picking it up. Where does that come from, is the threshold two and a half lakhs or five lakhs for him, and from when does it apply?

My client's EPF interest certificate now shows a taxable interest figure and the return utility is picking it up. Where does that come from, is the threshold two and a half lakhs or five lakhs for him, and from when does it apply?

It comes from the two provisos added to each of s.10(11) and s.10(12). The exemption does not apply to interest accrued during the previous year on so much of the person's own contribution as exceeds two lakh and fifty thousand rupees in any previous year in that fund, made on or after 1 April 2021; and the second proviso substitutes five lakh rupees for that figure where the contribution is to a fund in which there is NO contribution by the employer. So an ordinary EPF member whose employer contributes is on the Rs. 2,50,000 threshold, and a member of a fund to which the employer does not contribute — the General Provident Fund pattern — is on the Rs. 5,00,000 threshold. The computation is prescribed by Rule 9D, which requires separate taxable and non-taxable contribution accounts to be maintained within the provident fund account during previous year 2021-22 and all subsequent previous years, and which was inserted by the Income-tax (Twenty-fifth Amendment) Rules, 2021 with effect from 1 April 2022. Both provisos were inserted by clause (d) of section 6 of the Finance Act, 2021, with effect from 1 April 2022, so they first bite in assessment year 2022-23 even though the contributions they reach are those made on or after 1 April 2021.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2022-04-01, reported as Income-tax Act, 1961, ss.10(11) and 10(12), as printed on the departmental Year 2025 page; Income-tax Rules, 1962, rule 9D, as printed on the departmental rule page (no Year stamp), inserted by the Income-tax (Twenty-fifth Amendment) Rules, 2021 w.e.f. 1 April 2022. It bears on section 10(11), section 10(12), section Rule 9D, section 17(2)(vii) of the Income Tax Act 1961, in Salary & Perquisites and Capital Gains Exemptions matters.

Still good law. The two thresholds were read on three independent routes that agree: the provisos to clauses (11) and (12) as printed on the departmental Year 2025 edition of section 10; Explanation clause (c) to Rule 9D, read twice; and the Department's current explanatory page on retirement benefits, which states on its face that it is amended up to the Finance Act 2026 and describes the thresholds the same way round. That is the best evidence obtainable on this pass that the position holds for tax years up to AY 2026-27. The amending Act has now been read: clause (d) of section 6 of the Finance Act, 2021 inserted both provisos in both clauses with effect from 1 April 2022. The notification behind the Income-tax (Twenty-fifth Amendment) Rules, 2021 was not retrieved, so Rule 9D's commencement rests on the footnote printed on the departmental rule page, read twice on two different URL spellings. No judicial treatment of these provisos or of Rule 9D was located; a phrase search on "taxable contribution account" returned nothing.

Why it matters

This is the provision that turned the provident fund from a wholly tax-free vehicle into a partly taxable one, and it is easy to get the wrong way round. The five-lakh threshold is the HIGHER one and it applies where the employer does NOT contribute; the two-and-a-half-lakh threshold is the default and applies where the employer does. Practitioners who assume the higher figure belongs to the private-sector employee have it exactly backwards. Four further points matter in practice. First, the threshold bites on the CONTRIBUTION, not on the interest: what is taxed is the interest accrued on the excess contribution, not the excess contribution itself, and not interest on the balance built up before 1 April 2021. Second, Rule 9D's Explanation makes the non-taxable contribution account start from the closing balance as on 31 March 2021, so the entire pre-existing corpus and the interest on it stay outside the charge; only contributions from previous year 2021-22 onwards can feed the taxable account. Third, the taxable and non-taxable accounts are each reduced by withdrawals, so a withdrawal pattern changes the arithmetic and the fund's own certificate has to be checked rather than assumed. Fourth, the mechanism is annual and cumulative: once an excess contribution enters the taxable contribution account, the interest on it and on the interest already credited to that account continues to be taxable in later years. Note that these provisos sit inside the exemption clauses, so the charge falls under income from other sources on the interest and not as salary; and note that they are separate from s.17(2)(vii), which taxes the EMPLOYER's contribution above Rs. 7,50,000 as a perquisite — the two operate on different sides of the fund and both can apply in the same year.

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