Section 191 is the substantive equivalent of 1961 s. 111 -- the special-tax provision for RPF accumulated balance withdrawn by employee where Schedule XI Part A para 8 exemption is INAPPLICABLE (i.e., employee withdraws before 5 years of…
191
ITA 2025 · Section 191
Section 191 — - TAX ON ACCUMULATED BALANCE OF RECOGNISED PROVIDENT FUND
Section 191 is the substantive equivalent of 1961 s. 111 -- the special-tax provision for RPF accumulated balance withdrawn by employee where Schedule XI Part A para 8 exemption is INAPPLICABLE (i.e., employee withdraws before 5 years of continuous service / non-qualifying transfer). The AO computes tax as if (i) the RPF accumulated balance had been received by employee in earlier years (when contributions were made / accruals occurred) and (ii) compares to the actual tax assessed; the difference is added in current year. The provision avoids double-counting and ensures fair allocation of tax burden across the contribution years.
MECHANICS: where employee withdraws RPF accumulated balance and Schedule XI Part A para 8 (continuous-5-year service exemption) does NOT APPLY, the balance becomes taxable. The AO computes additional tax = (sum of taxes that would have been levied on the contributions and interest in respective years if treated as income then) MINUS (taxes actually assessed for those years). The differential is added in withdrawal year. Effect: tax burden re-allocated to contribution years for fair burden distribution. PRACTITIONER: track RPF withdrawal scenarios closely; non-qualifying withdrawal triggers reassessment; document Form 10C / Form 19 EPF withdrawal records.
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