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Case lawCirculars1996 › Circular No. 735
CBDT circular 30 January 1996

Circular No. 735

1008. Clarification regarding payment of income by way of interest on securities and rent made to Regimental Funds or Non-public Fund established by Armed Forces of Union for welfare of past and present members of such forces or their dependants, whose income is exempt under section 10(23AA)

What this is

Circular No. 735 was issued by the Central Board of Direct Taxes on 30 January 1996. Its subject is 1008. Clarification regarding payment of income by way of interest on securities and rent made to Regimental Funds or Non-public Fund established by Armed Forces of Union for welfare of past and present members of such forces or their dependants, whose income is exempt under section 10(23AA).

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

Directs that no tax be deducted at source under section 193 or section 194-I from the income of Regimental Funds or Non-public Funds established by the Armed Forces of the Union for the welfare of past and present members of those forces or their dependants. The reason given is that the income of these organisations is exempt under section 10(23AA). It therefore covers interest on securities and rent paid to or on behalf of such funds.

Why it was issued

The question of deduction at source under sections 193 and 194-I from income received by any person on behalf of such funds was brought to the Board's notice, and representations were received on behalf of Regimental and Non-public Funds.

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
s.193s.393
s.194s.2, s.393, s.397, s.400, s.402

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.

1008. Clarification regarding payment of income by way of interest on securities and rent made to Regimental Funds or Non-public Fund established by Armed Forces of Union for welfare of past and present members of such forces or their dependants, whose income is exempt under section 10(23AA)
1. The issue of deduction of income-tax at source under section 193 and section 194-I of the Income-tax Act from any income received by any person on behalf of any Regimental Fund or Non-public Fund established by the Armed Forces of Union for the welfare of past and present members of such forces or their dependants, has been brought to the notice of the Board. Repre­sentations have also been received on behalf of Regimental Funds and Non-public Fund established by the Armed Forces.
2. The matter with regard to regimental fund or non-public fund established by Armed Forces has been examined in the Board. Since the income of these organisations is exempt under section 10 (23AA) of the Income-tax Act, it has been decided that no tax may be deducted at source under sections 193 and 194-I from the income of such Funds.
Circular : No. 735, dated 30-1-1996.

What to watch

Where you meet it

In a TDS survey or an order under section 201 asking a payer why no tax was deducted on rent or interest paid to a regimental fund.

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. 736  ·  Circular No. 734 →

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.