VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — the substituted section 45(4): the firm is taxed on what a partner takes out above his capital account
CBDT Circulars & InstructionsCuts both wayss.45(4)s.9Bs.48s.48(iii)s.45(3)s.140s.139(1)

Statutory position — the substituted section 45(4): the firm is taxed on what a partner takes out above his capital account

A partner retired and we paid him Rs 2 crore, most of it out of a revaluation of the firm's land. He says it is his own capital. Is the FIRM taxable?

A partner retired and we paid him Rs 2 crore, most of it out of a revaluation of the firm's land. He says it is his own capital. Is the FIRM taxable?

Yes, on the excess. The substituted s.45(4) charges the FIRM to capital gains on money or a capital asset (or both) received by a partner in connection with a reconstitution, to the extent it exceeds the balance in his capital account — and that balance must be computed WITHOUT the increase caused by revaluation of any asset or by self-generated goodwill or any other self-generated asset. The formula is A = B + C − D, and if A is negative it is deemed to be zero, so a loss cannot be thrown up. Substituted by the Finance Act 2021 with effect from 1 April 2021, i.e. AY 2021-22.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2021-04-01, reported as Income-tax Act 1961, s.45(4) as substituted w.e.f. 1-4-2021 (AY 2021-22); Income-tax Rules 1962, rules 8AA(5) and 8AB, inserted by CBDT Notification No. 76/2021, G.S.R. 470(E), dated 2 July 2021. It bears on section 45(4), section 9B, section 48, section 48(iii), section 45(3), section 140, section 139(1) of the Income Tax Act 1961, in Capital Gains and How Tax Law Is Read matters.

Still good law. In force from AY 2021-22. No decision applying the substituted sub-section on its own facts was located: indiankanoon searches on 7 September 2026 for 'rule 8AB', for 'money or capital asset or both' with 'specified person', and for 'self-generated goodwill' with 'specified entity' and 'reconstitution' produced only bare-act pages and orders for years before AY 2021-22. Any decision on the PRE-2021 s.45(4) — including the leading authorities on distribution on retirement and on revaluation — construes a provision that no longer exists in that form and is now of historical interest only, save for assessment years up to AY 2020-21. I did not check for any writ challenge to the substituted provision or to the rules.

Why it matters

The old s.45(4) charged the firm on the DISTRIBUTION of a capital asset on dissolution 'or otherwise', and a generation of litigation turned on whether a retirement was a distribution and whether a revaluation credit was a transfer. The substituted provision abandons that ground entirely. It charges receipt by the partner, it expressly includes MONEY, and the second proviso strips the revaluation credit out of the very figure the firm would otherwise use to say nothing was taken out in excess. That single proviso reverses the commonest planning structure — revalue, credit the partners, pay out against the credited balance. Two consequences practitioners get wrong. First, Explanation 2 says the sub-section operates IN ADDITION to s.9B and that the taxation under the two is to be worked out INDEPENDENTLY — where a retiring partner takes a capital asset, both charges can arise on the one event and neither is set off against the other. Second, the gain does not float free: rule 8AA(5) fixes whether it is short or long term by reference to the asset it is attributed to, and rule 8AB attributes it to the assets REMAINING with the firm so that it becomes a cost under s.48(iii) when the firm later sells them. Miss rule 8AB and the firm pays tax twice on the same appreciation.

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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Related

Other authorities on the same sections.