Rule 206 — Rate of exchange for conversion into rupees of income expressed in foreign currency. Made under s.263 of the Income-tax Act, 2025.
Rule 206 gives effect to Section 263 of the Income-tax Act, 2025. A rule cannot go beyond the section it serves: where the two seem to differ, the section governs.
Sub-rule (1) fixes the rate of exchange for calculating the rupee value of any income accruing or arising, or deemed to accrue or arise, to the assessee in foreign currency, or received or deemed to be received by him or on his behalf in foreign currency, as the telegraphic transfer buying rate of that currency as on the specified date.
Sub-rule (2) takes "telegraphic transfer buying rate" from rule 207 and fixes the specified date by a Table of six entries. For income chargeable under the head "Salaries", it is the last day of the month immediately preceding the month in which the salary is due, or is paid in advance or in arrears. For income by way of interest on securities, it is the last day of the month immediately preceding the month in which the income is due. For income chargeable under the heads "Income from house property", "Profits and gains of business or profession" other than the income at entry 4, and "Income from other sources" excluding dividends and interest on securities, it is the last day of the tax year of the assessee. For income under "Profits and gains of business or profession" in the case of a non-resident engaged in the business of operation of ships, it is the last day of the month immediately preceding the month in which the income is deemed to arise in India. For income by way of dividends, it is the last day of the month immediately preceding the month in which the dividend is declared, distributed or paid by the company. For income chargeable under the head "Capital gains", it is the last day of the month immediately preceding the month in which the capital asset is transferred. Sub-clause (ii) provides that for income payable in foreign currency from which tax has been deducted at source under rule 207, the specified date is the date on which the tax was required to be deducted under the provisions of Chapter XIX-B.
Sub-rule (3) disapplies sub-rule (1) in respect of income falling in entry 3 of the Table where such income is received in, or brought into, India by the assessee or on his behalf before the specified date, in accordance with the provisions of the Foreign Exchange Regulation Act, 1973.
Income earned in a foreign currency has to be brought into a rupee computation, and the answer changes with the day chosen. The rule removes the choice: one rate, the telegraphic transfer buying rate, on one date fixed separately for each kind of income. The dates track the event that makes the income taxable — the month salary falls due, the month a dividend is declared, the month a capital asset is transferred — while heads of income that accrue through the year are converted at the last day of the tax year.
| What | Figure | The condition on it | Where |
|---|---|---|---|
| Rate of conversion | The telegraphic transfer buying rate of the currency as on the specified date | "Telegraphic transfer buying rate" has the meaning assigned to it in rule 207 | Sub-rule (1) with sub-rule (2)(a) |
| Specified date for income chargeable under "Salaries" | Last day of the month immediately preceding the month in which salary is due, or is paid in advance, or arrears | Income chargeable under the head "Salaries" | Sub-rule (2)(b), Table Sl. No. 1 |
| Specified date for interest on securities | Last day of the month immediately preceding the month in which the income is due | Income by way of interest on securities | Sub-rule (2)(b), Table Sl. No. 2 |
| Specified date for house property, business or profession and other sources income | Last day of the tax year of the assessee | Excluding the shipping income at entry 4, and excluding dividends and interest on securities under "Income from other sources" | Sub-rule (2)(b), Table Sl. No. 3 |
| Specified date for a non-resident in the business of operation of ships | Last day of the month immediately preceding the month in which the income is deemed to arise in India | Income chargeable under the head "Profits and gains of business or profession" | Sub-rule (2)(b), Table Sl. No. 4 |
| Specified date for dividends | Last day of the month immediately preceding the month in which the dividend is declared, distributed, or paid by the company | Income by way of dividends | Sub-rule (2)(b), Table Sl. No. 5 |
| Specified date for capital gains | Last day of the month immediately preceding the month in which the capital asset is transferred | Income chargeable under the head "Capital gains" | Sub-rule (2)(b), Table Sl. No. 6 |
| Specified date where tax has been deducted at source on income payable in foreign currency | The date on which the tax was required to be deducted under the provisions of Chapter XIX-B | Income payable in foreign currency from which tax has been deducted at source under rule 207 | Sub-rule (2)(b)(ii) |
The specified date is almost always the last day of the month before the month of the event, not the date of the event itself, so a salary due in June is converted at the rate on the last day of May. Entry 3 is the exception that works on the tax year, and it is also the only entry sub-rule (3) touches: where that income is received in or brought into India before the specified date in accordance with the Foreign Exchange Regulation Act, 1973, sub-rule (1) does not apply to it at all. The rule does not supply a rate of its own — the telegraphic transfer buying rate is defined in rule 207 — and where tax has been deducted at source under that rule, sub-clause (ii) moves the specified date to the date on which the tax was required to be deducted under Chapter XIX-B.
A resident individual is due salary of usd 10,000 for June 2026 from an overseas employer. Entry 1 of the Table fixes the specified date as 31 May 2026, so the amount is converted at the telegraphic transfer buying rate on that day, not at the rate on the day the salary is credited. If the same person sells foreign shares in September 2026, entry 6 converts the capital gain at the rate on 31 August 2026.
In the rupee figures reported in the return for foreign salary, dividends, interest or capital gains, and in any assessment where the Assessing Officer recomputes those figures at the prescribed rate and date.
shall be the telegraphic transfer buying rate of such currency as on the specified date
Last day of the month, immediately preceding the month in which dividend is declared, distributed, or paid by the company.