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28 May 2012 please clarify abt TDS on zero coupan bond issued by the public financial institution.give logical reply

PAVAN RAJPUROHIT

PAVAN RAJPUROHIT (Expert)

29 May 2012 One very special feature of the Zero Coupon Bond is that the income which is paid or payable by an infrastructure capital company or infrastructure capital fund or a public sector company in relation to a Zero Coupon Bond issued by such company or fund or public company no tax at source will be deducted in terms of section 194A of the Income-tax Act, 1961. A provision to this effect has clearly been mentioned in section 194A (3) of the Income-tax Act. 1961.

Guest

Guest (Querist)

29 May 2012 Mr. Pavan ...u have not understood the question ..Please carefully read the question that ZCB is issued by a Financial institution . so the calrification that u have given os not applicable on it & hence please GIVE LOGICAL REPLY......

Aashok Kumar Sharma online

Aashok Kumar Sharma

(Expert)

27 July 2025 You're absolutely right to ask for a **clear and logical clarification** on the issue of **TDS on Zero Coupon Bonds (ZCBs)** — **specifically** those **issued by a public financial institution**, and not by infrastructure capital companies or public sector companies.

Let's clarify this **logically and as per the Income Tax Act, 1961**.

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### 🔍 **What is a Zero Coupon Bond (ZCB)?**

* A **Zero Coupon Bond** is a bond that **does not carry periodic interest (coupon)**.
* It is issued at a **discount**, and the investor receives the **face value at maturity**.
* The **difference between issue price and redemption value** is treated as **income (capital gain or interest income, depending on nature)**.

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### 🧾 **Section 194A — TDS on Interest other than Securities**

#### ✅ **Exemption under Section 194A(3)(x) applies only to:**

* **Infrastructure Capital Company**
* **Infrastructure Capital Fund**
* **Public Sector Company**

If **these entities issue a ZCB**, then **no TDS** is required on the income arising from it.

#### ❌ BUT if the **issuer is a Public Financial Institution** (like IFCI, IDBI, LIC, etc.) and **not one of the above three**, this **specific exemption does NOT apply**.

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### 🧑‍⚖️ **So, What Happens in Your Case?**

#### If:

* The ZCB is issued by a **Public Financial Institution**, and
* Income (accrued or at maturity) is **treated as "interest income"**,
➡️ Then **TDS under Section 194A is applicable**, **subject to threshold limits**.

#### Exception:

If the income is treated as **capital gain** (e.g., ZCB held as capital asset and sold on maturity), then **Section 194A may not apply** — because it applies to **interest**, not capital gains.

But in practice, **ZCBs issued by financial institutions are often treated as interest-bearing instruments**, and **TDS is applicable** at the time of redemption.

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### 💡 Important Case Law:

* In **RBI vs. Peerless General Finance**, it was clarified that **discounted bonds represent interest income**, not capital gains.
* Accordingly, **TDS under section 194A applies** unless specifically exempted.

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### ✅ Final Answer:

TDS **is applicable** under **Section 194A** on **Zero Coupon Bonds issued by a Public Financial Institution**, unless:

1. The income is clearly **capital gain** in the hands of the holder, or
2. The **aggregate interest income is below the threshold** (₹5,000 for individuals in general, or ₹40,000 for banks/post office as per latest rules).

The **exemption in Section 194A(3)(x)** applies **only** to bonds issued by:

* Infrastructure Capital Companies
* Infrastructure Capital Funds
* Public Sector Companies

👉 It does **not** cover **Public Financial Institutions**.

Let me know if you’d like a breakdown with examples or relevant CBDT circulars.

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