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Case lawCirculars1991 › Circular No. 604
CBDT circular 11 June 1991

Circular No. 604

Interest income of non-resident Indians - Tax problems of non-resident Indians repatriated from Kuwait

What this is

Circular No. 604 was issued by the Central Board of Direct Taxes on 11 June 1991. Its subject is Interest income of non-resident Indians - Tax problems of non-resident Indians repatriated from Kuwait.

This grants an exemption or a relief under a provision that allows one. Read the conditions attached: an exemption notification is construed strictly, and a condition missed is the exemption lost.

What it does

Extends by three months the period for which returning Kuwait non-resident Indians keep the section 10(4)(ii) exemption on their non-resident external and foreign currency non-resident accounts. Circular No. 590 dated 30 January 1991 had given Indian nationals normally resident in Kuwait, forced back to India by the Iraqi invasion, the exemption in respect of such accounts maintained up to 31 March 1991. With hostilities over and the Reserve Bank permitting them to keep those accounts in India and their foreign currency accounts and assets abroad up to 30 June 1991, the Board clarifies that individuals normally resident in Kuwait who returned to India after 2 August 1990 are eligible for the exemption on such accounts maintained up to 30 June 1991.

Why it was issued

The Reserve Bank of India relaxed the account-holding position to help Kuwait non-resident Indians go back, and the Board matched the tax exemption to that relaxation.

Who it reaches

The provisions it speaks to

Left, the provision of the Income-tax Act, 1961 as the instrument itself names it. Right, the section of the Income-tax Act, 2025 that the department’s own concordance maps it to — which is where the same ground is now covered.
Under the 1961 ActNow
s.10s.11, s.19

The instrument, as the Board published it

The words below are the department’s own, reproduced from its published text. Where the department’s copy carried a publisher’s notes after the instrument, those are not reproduced.

Interest income of non-resident Indians - Tax problems of non-resident Indians repatriated from Kuwait
1. By Circular No. 590, dated 30-1-1991 (see Clarification 1), Indian nationals normally resident in Kuwait who were forced to return to India because of the Iraqi invasion, were made eligible for exemption under section 10(4)(ii ) of the Income-tax Act in respect of their NRE/FCNR accounts maintained by them up to 31st March, 1991.
2. With the cessation of hostilities in the Gulf and with a view to facilitate the Kuwait NRIs to return to Kuwait, RBI has now decided to permit them to continue to maintain their NRE/FCNR accounts in banks in India and to maintain their foreign currency accounts and assets abroad for a further period up to 30th June, 1991.
3. Taking into account the abovementioned factors, it is clarified that individuals normally resident in Kuwait and returning to India after 2nd August, 1990 would now be eligible for exemption under section 10(4)(ii) of the Income-tax Act in respect of such accounts maintained up to 30th June, 1991.
Circular : No. 604, dated 11-6-1991.

What to watch

Where you meet it

In an assessment for the year in which interest on a non-resident external or foreign currency non-resident account of a returned Kuwait non-resident Indian was brought to tax.

On the same provision

Other instruments in this library that name the same provision of the 1961 Act. They are not necessarily still operative, and a later one may have replaced an earlier one without saying so.

← Circular No. 605  ·  Circular No. 603 →

A circular binds the department, not you and not a court. The Board issues a circular to its own officers. An assessee may hold the department to a circular that helps him; the department cannot hold an assessee to one that hurts him, and the Tribunal and the courts decide the law for themselves.

Source: the Income Tax Department’s own published text — its page for this instrument.