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CA Final · Direct Tax Laws & International Taxation · Non Resident Taxation

A certificate under Rule 214 of the Income-tax Rules, 2026 issued to Kiran Traders for payments to a non-resident is valid up to 31 December. Kiran Traders wants to apply for a fresh certificate. Which is correct?

The payer may apply either within three months before the certificate expires or after it expires. Rule 214(5) gives this window for a fresh certificate, so applying a year in advance is not permitted, and renewal is not barred.

  1. AIt may apply within three months before 31 December or after expiryCorrect
  2. BIt may apply only after 31 December
  3. CIt may apply at any time, even a year before expiry
  4. DIt cannot apply since a certificate cannot be renewed

Explanation

Rule 214(5) permits an application for a fresh certificate after the expiry of the earlier certificate's validity or within three months before its expiry. So the window opens three months before 31 December, and continues after expiry. Applying a year early or being barred from renewal is not provided.

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