Guidelines under clause (23FE) of section 10 of the Income-tax Act, 1961

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... f section 10 of the Income-tax Act, 1961 - reg. Finance Act, 2020 , inter-alia , inserted clause (23FE) of section 10 of the Income-tax Act, 1961 (hereinafter referred to as the Act ) to provide for exemption to sovereign wealth funds and pension funds (hereinafter referred to as specified fund ) on their income in the nature of dividend, interest and long-term capital gains arising fr .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... or any other entity in the chain of holding or any associate thereof (hereinafter referred to as group concern ) has any loans or borrowings, the specified fund may be ineligible to get the exemption under the said clause. 4. First proviso to clause (23FE) of section 10 of the Act provides that if any difficulty arises regarding interpretation or implementation of the provisions of this cla .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... orrowings have been taken by the specified fund or any of its group concern, not specifically for the purposes of making investment in India, it shall not be presumed that the investment in India has been made out of such loans and borrowings and such specified fund shall be eligible for exemption under clause 23(FE) of section 10 of the Act, subject to the fulfilment of all other conditions und .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X