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The Sources of Public Revenue

Chapter Fifty-Eight

Syllabus topic 3.5, "Sources of Public Revenue"

Pages 379 to 385 of 556

In one line

A government's income comes from taxes, from what it earns and charges, and from what it borrows, and only the first two are revenue in the strict sense.

In the wording a student can write in an exam: the sources of public revenue are conventionally classified into tax revenue, comprising direct and indirect taxes, and non tax revenue, comprising fees, fines and penalties, special assessments, escheat, gifts and grants, income from public property and public enterprise, and receipts from currency and coinage; borrowing is not revenue in the strict sense but is a capital receipt which creates a liability, and the Union Budget accordingly classifies receipts into revenue receipts and capital receipts, the latter divided into debt and non debt receipts.

The classical classification

A. Tax revenue. A compulsory contribution imposed irrespective of the exact service rendered, as defined in [Public Finance and the Shape of the Indian Tax Structure]. Divided into direct and indirect, treated in the two preceding chapters.

B. Non tax revenue, which has seven heads and an examiner asks for them by name.

  1. Fees. Payments for a specific service rendered to the payer: court fees, passport fees, registration fees, licence fees. A quid pro quo exists, which is what distinguishes a fee from a tax.
  2. Fines and penalties. Levied for the infringement of a law. Their object is deterrence and not revenue, so a fine that yields a great deal is a sign of failure rather than success.
  3. Special assessment, also called a betterment levy. A compulsory charge on the owners of property whose value has risen because of a public improvement, such as a new road or drainage. It is compulsory like a tax and carries a benefit like a fee.
  4. Escheat. Property passing to the State on the death of a person leaving no heir and no will. Small in amount and always listed.
  5. Gifts and grants. Voluntary contributions, and grants from other governments or international bodies. In the Union accounts this appears as external grants, estimated at 2,327 crore rupees for 2026-27.
  6. Income from public property and public enterprise. Rent from government land, royalty from minerals, spectrum charges, and the dividends and profits of public sector undertakings and of the Reserve Bank. This is the largest non tax head in India: 3,91,000 crore rupees on the Budget Estimates for 2026-27.
  7. Receipts from currency, coinage and mint, including the profit on issuing coin whose metal is worth less than its face value, which is called seigniorage.

C. Borrowing, which is not revenue.

This is the distinction the whole topic turns on. Tax and non tax revenue are receipts that do not create a liability: the money is the Government's and nothing is owed. Borrowing creates a liability which must be serviced and repaid, so it is a capital receipt, and treating it as revenue is exactly the error that conceals a deficit. Article 292 authorises Union borrowing on the security of the Consolidated Fund within limits fixed by Parliament.

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The Budget's own classification

The Union Budget does not use the classical headings. It divides receipts as follows, and a student should be able to move between the two.

Budget headWhat it containsBudget Estimate 2026-27, crore rupees
Revenue receiptsTax revenue net of the States' share, plus non tax revenue35,33,150
of which Centre's net tax revenueGross tax revenue minus the States' share and the disaster fund transfer28,66,922
of which non tax revenueInterest receipts, dividends and profits, external grants, other non tax revenue, receipts of Union territories6,66,228
Capital receipts, non debtRecovery of loans, and disinvestment1,18,397
Capital receipts, debtBorrowing of every kind16,63,066
Draw down of cash balance32,702
Total receipts53,47,315

The gross tax revenue and what happens to it, which is the most instructive row in the Budget.

Budget Estimate 2026-27, crore rupees
Gross tax revenue44,04,086
Less National Calamity Contingent Duty transferred to the disaster funds10,910
Less States' share15,26,255
Centre's net tax revenue28,66,922

Read that table twice. More than a third of the Union's gross tax revenue never belongs to the Union at all: it is the States' share under article 270, determined on the Finance Commission's recommendation. An answer that quotes gross tax revenue as the Union's income has overstated it by about 15 lakh crore rupees.

Non tax revenue in detail

From the Budget Estimates for 2026-27, in crore rupees.

HeadAmount
Dividends and profits3,91,000
Other non tax revenue2,29,373
Interest receipts41,763
External grants2,327
Receipts of Union territories1,765
Total non tax revenue6,66,228

Dividends and profits is by far the largest, and the greater part of it is the surplus transferred by the Reserve Bank of India together with dividends from public sector banks and undertakings. Its size explains why the Reserve Bank's surplus transfer is a fiscal event and not merely a monetary one.

Capital receipts

Non debt capital receipts, which do not create a liability:

  • Recovery of loans made by the Union to States and others.
  • Disinvestment, the sale of the Government's equity in public sector undertakings. Note that this converts an asset into cash: it finances the deficit without creating a liability, but it also reduces future dividend income.

Debt capital receipts, which do create a liability. From the Budget's financing statement for 2026-27, in crore rupees:

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The Sources of Public Revenue

SourceAmount
Market borrowings, government securities11,73,210
Securities against small savings3,86,772
Short term borrowing, treasury bills and the like1,30,000
State provident funds3,500
External debt15,385
Other receipts, internal debt and public accountminus 45,801
Debt receipts, net16,63,066

Two things to notice. Market borrowing through dated government securities is the dominant source, which is why the government securities market is the foundation of the interest rate structure, as [The Indian Money Market: Structure and Instruments] explains. And external debt is very small, at 15,385 crore rupees, so India's Union borrowing is overwhelmingly domestic and in its own currency, which removes the exchange rate risk that afflicts many developing countries.

Two constitutional funds and a third

  • The Consolidated Fund of India, article 266(1). All revenues received, all loans raised by treasury bills, loans or ways and means advances, and all money received in repayment of loans. Withdrawal only under appropriation made by law.
  • The Public Account of India, article 266(2). Money received by or on behalf of the Government where it acts as a banker rather than an owner: provident funds, small savings, deposits. It is not the Government's money, and expenditure from it needs no appropriation.
  • The Contingency Fund of India, article 267. An imprest placed at the disposal of the President to meet unforeseen expenditure pending authorisation by Parliament.

A worked example: classifying eight receipts

ReceiptClassical headBudget head
Goods and services tax collectedTax revenue, indirectRevenue receipt
Corporation taxTax revenue, directRevenue receipt
Court fee on a plaintNon tax, feeRevenue receipt
Penalty for late filing of a returnNon tax, fineRevenue receipt
Dividend from a public sector bankNon tax, income from public enterpriseRevenue receipt
Sale of the Government's shares in a companyNot revenue; conversion of an assetCapital receipt, non debt
Issue of a ten year government securityNot revenue; creates a liabilityCapital receipt, debt
Provident fund subscription received from an employeeNot the Government's money at allPublic Account, not the Consolidated Fund

The last three rows are where marks are won. Disinvestment and borrowing both bring cash and neither is revenue: one sells an asset, the other creates a liability. And a provident fund subscription is not a receipt of the Government in any sense; it is held as a banker under article 266(2).

Which sources are good sources

The criteria, drawn from the canons in [Public Finance and the Shape of the Indian Tax Structure]:

  1. Adequacy. Enough to meet the expenditure.
  2. Elasticity. Rising automatically with national income, which taxes on income do and a fixed fee does not.
  3. Equity. Falling more heavily on those better able to bear it.
  4. Economy of collection.
  5. Certainty and stability. A source that swings with commodity prices or with a single company's profits is a poor foundation.
  6. Non distorting. A tax that changes behaviour a great deal for a small yield is a bad tax, unless changing that behaviour is the object.
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Judged against these, the Indian structure rests principally on taxes on income, which are elastic and progressive, and on the goods and services tax, which is broad based and stable. Its weakest features are the dependence on a few large sources of non tax revenue, chiefly the Reserve Bank surplus and dividends, which can vary sharply from year to year, and the size of borrowing relative to revenue.

What beginners get wrong

"Borrowing is a source of public revenue." It is a capital receipt that creates a liability. Only tax and non tax receipts are revenue in the strict sense, and the Budget separates them for exactly this reason.

"Disinvestment is revenue." It is a non debt capital receipt: an asset is converted into cash. It creates no liability but it reduces future income.

"Gross tax revenue is the Union's income." More than a third of it, 15,26,255 crore rupees for 2026-27, is the States' share under article 270 and never belongs to the Union.

"Fees and taxes are the same because both are compulsory." A fee is payable for a specific service taken, and a quid pro quo can be shown. A tax carries no specific return.

"The Public Account is part of government revenue." It is money the Government holds as a banker under article 266(2), such as provident fund balances, and it is not its own.

Limits

The classical heads and the Budget heads do not correspond, so an answer must say which classification it is using.

Non tax revenue is volatile. The largest item, dividends and profits, depends substantially on the Reserve Bank's surplus, which varies with its balance sheet and with exchange rate movements.

Disinvestment receipts are unpredictable, since they depend on market conditions and on decisions that may be postponed.

Figures are Budget Estimates and will be revised.

Quick revision

  1. Classical classification: tax revenue, direct and indirect; non tax revenue under seven heads, being fees, fines and penalties, special assessment, escheat, gifts and grants, income from public property and enterprise, and receipts from currency and coinage; and borrowing, which is not revenue.
  2. The crucial distinction: tax and non tax revenue create no liability; borrowing does. Article 292 authorises Union borrowing within limits fixed by Parliament.
  3. Budget classification, 2026-27 Budget Estimates: revenue receipts 35,33,150 crore, being Centre's net tax revenue 28,66,922 and non tax revenue 6,66,228; non debt capital receipts 1,18,397; debt receipts 16,63,066; draw down of cash 32,702; total receipts 53,47,315 crore.
  4. Gross tax revenue 44,04,086 crore, less the disaster fund transfer of 10,910 and the States' share of 15,26,255, leaves the Centre's net tax revenue at 28,66,922 crore. More than a third never belongs to the Union.
  5. Largest non tax head: dividends and profits, 3,91,000 crore, chiefly the Reserve Bank surplus and public sector dividends.
  6. Borrowing is dominated by market borrowing through government securities, 11,73,210 crore, with external debt only 15,385 crore, so Union debt is overwhelmingly domestic and rupee denominated.
  7. Three funds: the Consolidated Fund (article 266(1)), the Public Account (article 266(2)) and the Contingency Fund (article 267).
  8. Criteria for a good source: adequacy, elasticity, equity, economy, certainty and stability, and minimal distortion.
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Test yourself

1. Classify the sources of public revenue. Public revenue is classified into tax revenue and non tax revenue, with borrowing standing outside the classification as a capital receipt. Tax revenue consists of direct taxes, principally the taxes on income and corporation tax, and indirect taxes, principally the goods and services tax, Union excise duties and customs. Non tax revenue has seven heads: fees, which are payments for a specific service rendered to the payer, such as court and passport fees; fines and penalties, imposed for infringement of law and intended to deter rather than to raise money; special assessment or betterment levy, a compulsory charge on owners whose property has gained value from a public improvement; escheat, property passing to the State for want of an heir; gifts and grants, including grants from foreign governments and international bodies; income from public property and public enterprise, including rent, royalties, spectrum charges and the dividends and profits of public undertakings and of the Reserve Bank; and receipts from currency, coinage and mint, including seigniorage.

2. Why is borrowing not treated as public revenue? Because it creates a liability. Tax and non tax receipts belong to the Government absolutely and nothing is owed in respect of them, so they can be spent without any future consequence for the exchequer. A loan must be serviced by interest payments and eventually repaid, so the receipt of it is matched by an obligation, and to treat it as revenue would be to conceal the deficit which the borrowing exists to finance. The Union Budget therefore classifies receipts as revenue receipts on the one hand and capital receipts on the other, and divides the latter into debt receipts, which create a liability, and non debt receipts such as recovery of loans and disinvestment, which do not. Article 292 of the Constitution authorises the executive power of the Union to extend to borrowing upon the security of the Consolidated Fund within such limits as Parliament may fix.

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3. Distinguish a fee, a fine and a special assessment from a tax. A tax is compulsory and carries no specific return to the payer. A fee is a payment for a specific service rendered to the payer, so a quid pro quo exists and the payment arises only if the service is taken, as with a court fee or a passport fee. A fine or penalty is compulsory, but is imposed for the infringement of a law and its object is deterrence rather than revenue, so a high yield from fines indicates that the law is being broken rather than that the levy is successful. A special assessment is compulsory like a tax, but is levied on a defined class of property owners whose property has risen in value because of a specific public improvement, so it carries a benefit to the payer's property in a way a tax does not.

4. What happens to the Union's gross tax revenue before it becomes the Centre's income? On the Budget Estimates for 2026-27, gross tax revenue is 44,04,086 crore rupees. From it is deducted the National Calamity Contingent Duty of 10,910 crore, which is transferred to the National Calamity Contingency Fund and the National Disaster Response Fund, and the States' share of 15,26,255 crore, which is devolved under article 270 in the proportion recommended by the Finance Commission. What remains, 28,66,922 crore rupees, is the Centre's net tax revenue. More than a third of the gross figure therefore never belongs to the Union at all, and an answer that treats gross tax revenue as the Union's income overstates it by about fifteen lakh crore rupees.

5. What are the components of the Union's borrowing, and what is significant about them? On the Budget Estimates for 2026-27, net debt receipts of 16,63,066 crore rupees comprise market borrowings through dated government securities of 11,73,210 crore, securities issued against small savings of 3,86,772 crore, short term borrowing through treasury bills and the like of 1,30,000 crore, State provident funds of 3,500 crore, external debt of 15,385 crore, and a negative 45,801 crore from other internal debt and public account items. Two features are significant. Market borrowing through government securities dominates, which is why the market in those securities determines the whole structure of interest rates in the economy. And external debt is very small in this total, so the Union's borrowing is overwhelmingly domestic and denominated in rupees, which means it carries no exchange rate risk of the kind that has repeatedly caused crises in countries that borrow abroad in foreign currency.

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6. Distinguish the Consolidated Fund, the Public Account and the Contingency Fund. The Consolidated Fund of India, under article 266(1), comprises all revenues received by the Government of India, all loans raised by it by the issue of treasury bills, loans or ways and means advances, and all money received in repayment of loans; no money may be withdrawn from it except under an appropriation made by law. The Public Account of India, under article 266(2), holds money received by or on behalf of the Government in which it acts as a banker rather than as owner, such as provident fund balances, small savings and deposits; the money is not the Government's own and expenditure from it does not require parliamentary appropriation. The Contingency Fund of India, under article 267, is an imprest placed at the disposal of the President to enable unforeseen expenditure to be met pending authorisation by Parliament, the amount being recouped once Parliament sanctions it.

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