VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.10(13) on the approved superannuation fund, and s.17(2)(vii)/(viia): the Rs. 7,50,000 AGGREGATE ceiling on the employer's contribution to provident fund, NPS and superannuation taken together, and the annual accretion on it
CBDT Circulars & InstructionsCuts both waysValidity unconfirmeds.10(13)s.17(2)(vii)s.17(2)(viia)s.17(3)(ii)s.80CCDs.80CCD(1)s.10(11)s.10(12)Rule 3B

Statutory position — s.10(13) on the approved superannuation fund, and s.17(2)(vii)/(viia): the Rs. 7,50,000 AGGREGATE ceiling on the employer's contribution to provident fund, NPS and superannuation taken together, and the annual accretion on it

My client's Form 16 now shows a perquisite for the employer's contribution to the superannuation fund and to NPS. Is there a separate limit for each fund, and what is the extra line for annual accretion?

My client's Form 16 now shows a perquisite for the employer's contribution to the superannuation fund and to NPS. Is there a separate limit for each fund, and what is the extra line for annual accretion?

There is one limit, not three. Section 17(2)(vii) makes the amount or the aggregate of amounts of any contribution made to the assessee's account by the employer in a recognised provident fund, in the scheme referred to in s.80CCD(1) and in an approved superannuation fund a perquisite to the extent it exceeds seven lakh and fifty thousand rupees in a previous year — a single aggregate figure across all three. Section 17(2)(viia) then makes the annual accretion by way of interest, dividend or any other amount of similar nature during the previous year to the balance at the credit of those funds a further perquisite, to the extent it relates to the contribution already taxed under sub-clause (vii), computed in the manner prescribed. Separately, s.10(13) exempts payments out of an approved superannuation fund on the death of a beneficiary, to an employee in lieu of or in commutation of an annuity on retirement at or after a specified age or on incapacity, by way of refund of contributions on death, by way of refund of contributions on leaving service otherwise than by such retirement or incapacity to the extent the payment does not exceed the contributions made before the commencement of the Act and interest on them, and by way of transfer to the employee's account under a pension scheme referred to in s.80CCD and notified by the Central Government. Both sub-clauses date from 1 April 2021: section 13 of the Finance Act, 2020 substituted sub-clause (vii) and inserted sub-clause (viia) with effect from that date, so the aggregate ceiling first applies for assessment year 2021-22. Before that, sub-clause (vii) reached only the employer's contribution to an approved superannuation fund and only above one lakh and fifty thousand rupees, and there was no sub-clause (viia) at all.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2021-04-01, reported as Income-tax Act, 1961, s.17(2)(vii) and (viia) as printed on the departmental Year 2025 and Year 2024 (No. 1) pages; s.10(13) as printed on the departmental Year 2018 page. It bears on section 10(13), section 17(2)(vii), section 17(2)(viia), section 17(3)(ii), section 80CCD, section 80CCD(1), section 10(11), section 10(12), section Rule 3B of the Income Tax Act 1961, in Salary & Perquisites and Capital Gains Exemptions matters.

Validity check could not be completed. Validity check could not be completed, and the reason is specific rather than general. Section 17(2)(vii) and (viia) were read on two departmental editions a year apart which print them identically, and the Rs. 7,50,000 figure also appears on the Department's current explanatory page, amended on its face up to the Finance Act 2026; and the date has now been established from section 13 of the Finance Act, 2020 ("with effect from the 1st day of April, 2021"), corroborated by year-stamped departmental editions on either side of that date. Rule 3B has also been retrieved, at https://incometaxindia.gov.in/w/rule-3b-2, with its formula and the footnote "Inserted by the IT (First Amdt.) Rules, 2021, w.e.f. 1-4-2021". What remains unverified is section 10(13): it could be read only on archived Year 2018 and Year 2019 (No. 1) editions, because the current section 10 page truncates before it and has twice fabricated a substitute clause in its place; its continued existence in the current text is supported by the cross-reference to it in s.17(3)(ii) on the Year 2025 section 17 page, by the Delhi High Court's quotation of s.10(13)(ii) in S.D.S. Mongia, and by the fact that section 6 of the Finance Act, 2021 does not amend it. I did not carry out any check of judicial treatment of s.17(2)(vii) or (viia).

Why it matters

Two mistakes recur. The first is treating the Rs. 7,50,000 as three separate allowances; it is one aggregate across the recognised provident fund, the s.80CCD(1) scheme and the approved superannuation fund, so a senior employee with generous contributions to all three can be well over the line even though no single fund looks excessive. The second is forgetting sub-clause (viia): once an excess contribution has been taxed under sub-clause (vii) in any previous year, the annual accretion referable to it is a perquisite in every later year, so the charge is recurring and not one-off, and the phrase "which is included in total income under the said sub-clause in any previous year" carries that forward. Note the boundaries. Section 17(2)(vii) taxes the EMPLOYER's contribution; the provisos to s.10(11) and s.10(12) tax the interest on the EMPLOYEE's own contribution above Rs. 2,50,000 or Rs. 5,00,000 — different sides of the fund, both potentially in the same year. Section 10(13) is a payment-out provision, and its sub-clause (iv) is narrower than it looks: a refund of contributions to an employee who leaves service otherwise than by retirement at or after a specified age or on incapacity is exempt only to the extent of contributions made BEFORE the commencement of the Act and interest on them, which for practical purposes means almost nothing today. Sub-clause (v) is the one that makes a transfer from a superannuation fund into a notified pension scheme under s.80CCD tax-neutral. And note that s.17(3)(ii) expressly carves payments referred to in clause (13) of section 10 out of profits in lieu of salary, so a payment inside s.10(13) is not brought back in by that route.

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.