VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.80CCD(1B) and s.80CCD(2): the fifty-thousand NPS deduction that does NOT survive s.115BAC(1A), the employer contribution that does, and the fourteen per cent proviso inserted by Act No. 15 of 2024
CBDT Circulars & InstructionsCuts both wayss.80CCDs.80CCD(1)s.80CCD(1B)s.80CCD(2)s.115BACs.115BAC(1A)s.115BAC(2)s.80CCH(2)s.80JJAAs.17(2)(vii)

Statutory position — s.80CCD(1B) and s.80CCD(2): the fifty-thousand NPS deduction that does NOT survive s.115BAC(1A), the employer contribution that does, and the fourteen per cent proviso inserted by Act No. 15 of 2024

My client is in the default regime under s.115BAC. Can he still claim the extra fifty thousand for NPS, and what is the ceiling on his employer's NPS contribution now?

My client is in the default regime under s.115BAC. Can he still claim the extra fifty thousand for NPS, and what is the ceiling on his employer's NPS contribution now?

No on the first, better news on the second. Section 115BAC(2)(i) computes the total income of a person taxed under s.115BAC(1A) without any deduction under Chapter VI-A other than sub-section (2) of section 80CCD, sub-section (2) of section 80CCH and section 80JJAA — so the additional Rs. 50,000 deduction under s.80CCD(1B) is not available in the default regime, while the employer's contribution deduction under s.80CCD(2) is. On the ceiling: s.80CCD(2) allows fourteen per cent of salary where the contribution is made by the Central Government or a State Government and ten per cent where it is made by any other employer, but a proviso inserted by Act No. 15 of 2024 with effect from 1 April 2025 provides that where the total income is chargeable to tax under s.115BAC(1A), sub-section (2) has effect as if for the words "ten per cent" in clause (b) the words "fourteen per cent" had been substituted.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2025-04-01, reported as Income-tax Act, 1961, s.80CCD, as printed on the departmental Year 2025 page with its footnote; s.115BAC(2)(i), as printed on the departmental Year 2025 and Year 2024 (No. 1) pages. It bears on section 80CCD, section 80CCD(1), section 80CCD(1B), section 80CCD(2), section 115BAC, section 115BAC(1A), section 115BAC(2), section 80CCH(2), section 80JJAA, section 17(2)(vii) of the Income Tax Act 1961, in Salary & Perquisites and Deductions & Disallowances matters.

Still good law. The restriction in s.115BAC(2)(i) was read on two departmental editions a year apart which print the same closing words naming s.80CCD(2), s.80CCH(2) and s.80JJAA as the only Chapter VI-A survivors. The s.80CCD(2) proviso and its commencement come from the Year 2025 page's own amendment footnote, "Ins. by Act No. 15 of 2024, w.e.f. 1-4-2025", which was demanded expressly; the Year 2023 edition of s.80CCD does not carry the proviso, which is independent year-stamped support for that date. No Finance Act text was retrieved this pass and the footnote is the only evidence for the enacting Act, so a reader who needs certainty should check Act No. 15 of 2024 itself. The second proviso to s.80CCD(1B) is printed as one that "shall be inserted" by the Finance Act 2025 with effect from 1 April 2026; it is stated here as the page states it and has not been verified against the Finance Act. I did not carry out any check of judicial treatment of s.80CCD or s.115BAC.

Why it matters

This is the planning decision every salaried client now faces, and the two sub-sections point in opposite directions. Section 80CCD(1B) is the employee's own additional Rs. 50,000, allowed whether or not a deduction is allowed under sub-section (1), with a proviso barring a double deduction for an amount already claimed and allowed under sub-section (1) — and it is simply gone in the default regime. Section 80CCD(2) is the employer's contribution, and not only does it survive s.115BAC, it is worth MORE there for a private-sector employee: from assessment year 2025-26 the private-employer limit rises from ten to fourteen per cent of salary if the employee's income is chargeable under s.115BAC(1A). That is a real reason to restructure a salary package into employer NPS contribution for a client who has moved to the default regime. Three cautions. First, the fourteen per cent for a Government employer under clause (a) is unconditional and does not depend on the regime; the proviso only lifts clause (b). Second, s.80CCD(2) is a deduction of the employer's contribution, and the same contribution is a perquisite under s.17(2)(vii) so far as the aggregate of employer contributions to the recognised provident fund, the s.80CCD(1) scheme and an approved superannuation fund exceeds Rs. 7,50,000 — the deduction and the perquisite charge are separate provisions and both apply. Third, the departmental page prints a second proviso to sub-section (1B), to be inserted by the Finance Act 2025 with effect from 1 April 2026, extending the deduction to a payment or deposit made by a parent or guardian to the account of a minor under the pension scheme, with the aggregate deduction under the sub-section still not exceeding Rs. 50,000 — note that it takes effect from assessment year 2026-27 and, on the same reasoning as above, sub-section (1B) remains outside s.115BAC(1A).

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