Section 89 / Section 157 Relief on Salary Arrears (Form 10E / Form 39)
Work out the relief available when salary arrears or advance push you into a higher tax bracket in the year of receipt.
Law version: FY 2025-26 (Income-tax Act, 1961); Tax Year 2026-27 onwards (Income-tax Act, 2025). Checked on 26 Sep 2026.
What it is
When salary for earlier years is received in arrears, or salary is received in advance, the whole amount is taxed in the year of receipt, which can mean a higher rate. Relief is available by comparing the extra tax in the year of receipt with the extra tax if the arrears had been taxed in the years they relate to. The claim is made under Section 89(1) with Form 10E for FY 2025-26, and under Section 157 with Form 39 from Tax Year 2026-27. The form must be filed before the return.
When it is used
- Arrears from a pay revision or delayed increment.
- Family pension arrears or gratuity received in arrears.
- Salary received in advance.
What the template covers
- Employee name, PAN and employer
- Year of receipt
- Nature and amount of arrears
- Years to which the arrears relate
- Tax with and without the arrears in each year
- Relief claimed
Details you will need
The generator asks for the following. Fields marked with an asterisk in the form are required; the rest can be left blank and filled in later in Word.
Declaration
Date
Assessee
Employee Name; PAN; Employer Name; Year of receipt (FY / Tax Year)
Arrear
Nature of Arrear / Advance; Total Arrear Amount Received (₹); Arrear relates to FY from; Arrear relates to FY to
Computation
Tax on Total Income in Current Year (with arrear, ₹); Tax on Total Income in Current Year (EXCLUDING arrear, ₹); Tax on Past Year Incomes (as if arrear was included then, ₹); Actual Tax on Past Year Incomes (without arrear, ₹); Relief under Section 89(1) Claimed (₹)
Stamp duty, registration and filing
If the relief is claimed without filing the form, the department may disallow it on processing. The employer can also give relief while deducting TDS if the employee provides the details. Use the tax rates and regime for each past year in the computation. Check the current form on incometax.gov.in.
Relief is claimed under Section 89(1) with Form 10E for FY 2025-26, and under Section 157 with Form 39 from Tax Year 2026-27. The form must be filed before the return.
Generate the Section 89 / Section 157 Relief — Salary Arrears (Form 10E / Form 39)
Fill in the form and download the draft as a Word file. It is a general template, not legal or professional advice; have it reviewed for your facts before you sign or rely on it.
Need this checked against your facts, or the registration or filing that follows (e.g. TDS returns, ITR)? Contact SKAG and Associates
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Frequently asked questions
Is filing Form 10E mandatory?
Yes, to claim relief under Section 89(1). From Tax Year 2026-27 the form is Form 39.
Can relief be claimed for arrears of any income?
It applies to salary, including family pension, received in arrears or advance, and certain other salary items.
What if relief works out to nil?
Relief is available only if the tax in the year of receipt is higher because of the arrears.
This page gives general information for reference only. Laws, stamp duty rates and filing requirements change and differ between States, so confirm the current position for your case. Related: all document templates · free tax calculators · compliance calendar and guides.