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

Kaveri Traders Ltd holds a Rule 214 certificate expiring on 30 September. Under Rule 214(5) of the Income-tax Rules, 2026, when may it apply for a fresh certificate?

Kaveri may apply for a fresh certificate either after the earlier certificate expires or within three months before its expiry. Rule 214(5) therefore lets it apply from about 30 June onwards, and cancellation of the earlier certificate is not a precondition.

  1. AOnly after 30 September, once the certificate has expired
  2. BAfter the expiry, or within three months before the expiry of the earlier certificateCorrect
  3. COnly within one month before the expiry
  4. DOnly after the Assessing Officer cancels the earlier certificate

Explanation

Rule 214(5) allows a fresh application after the period of validity of the earlier certificate has expired, or within three months before its expiry. Hence the window opens three months before 30 September and continues after expiry. Restricting to only after expiry or only one month before misstates the rule.

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