14. Explain the distinguishing features of “Capital receipt” and “Revenue receipt”

"Capital receipt" and "Revenue receipt".,

Understanding the Distinction Between Capital Receipts and Revenue Receipts under Indian Income Tax Law

When it comes to taxation and accounting, distinguishing between capital receipts and revenue receipts is fundamental. The classification not only impacts taxability but also the financial health of individuals, companies, and government bodies. While both types of receipts involve inflow of money or benefits, their nature, source, and tax treatment differ significantly.

In this article, we’ll explain both capital and revenue receipts with relatable examples, relevant legal references, and help you understand their impact on income tax computations. Whether you are a student, tax professional, or business owner, this guide will clarify a crucial aspect of financial law and accounting.


What is a Receipt in Tax Terms?

In the context of taxation, a receipt refers to any inflow of money, assets, or benefits received by a taxpayer—either as a result of running a business, selling assets, receiving grants, or other activities. Under the Income Tax Act, 1961, how a receipt is categorized determines its taxability.


What Are Capital Receipts?

Capital Receipts are those receipts which:

  • Are non-recurring in nature
  • Either create a liability or reduce assets
  • Do not arise from normal operations of a business
  • Are generally not taxable, unless specifically included under the Income Tax Act

Examples of Capital Receipts

  • Amount received from sale of fixed assets
  • Loan taken from a bank or financial institution
  • Capital contribution from partners in a firm
  • Government grants for asset creation
  • Compensation for loss of capital assets

What Are Revenue Receipts?

Revenue Receipts are receipts that:

  • Are recurring in nature
  • Arise from the normal course of business or profession
  • Do not create liabilities or reduce assets
  • Are generally taxable, unless exempted

Examples of Revenue Receipts

  • Sale of goods or services
  • Commission income
  • Interest received
  • Rent received
  • Dividends

Key Distinguishing Features of Capital and Revenue Receipts

CriteriaCapital ReceiptRevenue Receipt
NatureNon-recurringRecurring
SourceNot from normal business operationsFrom regular business or profession
Impact on Asset/LiabilityAffects capital structure (asset/liability)No direct effect on capital structure
TaxabilityGenerally not taxable (exceptions apply)Usually taxable (unless specifically exempt)
ExamplesSale of land, loan received, capital subsidySale revenue, rent, interest, dividend
Accounting TreatmentAppears on Balance SheetRecorded in Profit & Loss Account

Legal Provisions and Judicial View

Although the Income Tax Act, 1961 does not define capital or revenue receipts explicitly, the distinction has been clarified through case laws and judicial interpretations. Courts have laid down principles such as:

  • Kettlewell Bullen and Co. Ltd. v. CIT: Compensation received for loss of capital asset is capital receipt.
  • CIT v. Rai Bahadur Jairam Valji: Compensation for termination of business contracts is capital receipt.

Additionally, Sections like 2(24) of the Income Tax Act define income and include certain capital receipts (e.g., winnings from lotteries, capital gains), making them taxable under specified heads.


When Capital Receipts Become Taxable

Some capital receipts are specifically taxed under Income Tax Act, such as:

  • Capital Gains (Section 45): Gains from sale of capital assets
  • Securities Premium exceeding fair market value (Section 56(2)(viib))
  • Gifts exceeding ₹50,000 received without consideration (Section 56(2)(x))

Hence, though capital receipts are generally non-taxable, exceptions exist where they are taxed due to potential misuse or revenue potential.


Importance in Government Accounting

In public finance, the distinction is used for budgetary classifications:

  • Capital Receipts: Include borrowings, disinvestment, recovery of loans—used to finance asset creation.
  • Revenue Receipts: Include tax collections, interest, dividends—used for day-to-day functioning.

This helps the government maintain fiscal discipline and measure fiscal deficit accurately.


Practical Example for Clarity

Let’s assume a company:

  • Sells old machinery for ₹5 lakh → Capital Receipt
  • Receives ₹10 lakh from selling products → Revenue Receipt
  • Takes a loan of ₹15 lakh from a bank → Capital Receipt
  • Earns ₹50,000 in bank interest → Revenue Receipt

Only the sale proceeds and interest income would be taxable as revenue receipts. Loan and machinery sale proceeds would be non-taxable unless capital gains arise.


Key Takeaways

  1. Capital Receipts are non-recurring, often non-taxable, and affect financial structure.
  2. Revenue Receipts are recurring, form part of income, and are usually taxable.
  3. Classification affects tax liability and financial reporting.
  4. Income Tax Act and case laws together define how these receipts are treated.
  5. Misclassification can lead to tax penalties or wrong assessments.

Mnemonic :

Mnemonic to Remember the Difference: “CAP-REC” vs. “REV-IN”

MnemonicStands For
CAP-RECCapital Receipt: Affects Capital, Rare, Exceptional, Not Regular, Earnings once or special circumstances
REV-INRevenue Income: Repeating, Earnings from business, Valuable, Immediate use, Normal

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