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TMI BlogIncome of a specified person arising from an investment made in India - Sovereign wealth fund Norges Bank On Account Of The Government Pension Fund Global notfied as the specified person.X X X X Extracts X X X X X X X X Extracts X X X X ..... e Government Pension Fund Global (PAN: AACCN1454E), (hereinafter referred to as the assessee ) as the specified person for the purposes of the said clause in respect of the investment made by it in India on or after the date of publication of this notification in the Official Gazette but on or before the 1 [ 31st day of March, 2025 ] (hereinafter referred to as the said investments ) subject to the fulfilment of the following conditions, namely:- (i) the assessee shall file return of income, for all the relevant previous years falling within the period beginning from the date on which the said investment has been made and ending on the date on which such investment is liquidated, on or before the due date specified for furnishing the return ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... overnment of Norway or to any other account designated by that Government so that no portion of the earnings inures any benefit to any private person, barring any payment made to creditors or depositors for loan taken or borrowing [as defined in sub-clause (a) of clause (ii) of Explanation 2 to clause (23FE) of section 10 of the Act] made for purposes other than for making investment in India; (viii) the assessee shall not have any loan or borrowing [as defined in sub-clause (a) of clause (ii) of Explanation 2 to clause (23FE) of section 10 of the Act], directly or indirectly, for the purposes of making investment in India; (ix) the asset of the assessee shall vest in the Government of Norway upon dissolution, barring any payment made to cr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as laid down under clause (23FE) of section 10 of the Income-tax Act, 1961 (hereinafter referred to as the Act ) and those provided in the said notification specifying the assessee being the Sovereign Wealth Fund as specified person for the purposes of claiming exemption under the said clause (23FE) of the Act. 2.1 *The conditions not complied with by the assessee are as under:- (a) . . (b) . . 3. In *my/our opinion and to the best of *my/ our information and according to examination of books of account including other relevant documents and explanations given to *me/us, the particulars given in the Part II are true and correct subject to the following observations/qualifications, if any, namely:- (a) . . (b) . . Part II 1. Name of the Ass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mption/the SWF has sold certain investments made for the purposes of exemption under clause (23FE) of section 10 of the Act before the expiry of three years from the date on which the investment was made in respect of the said exemption, the details of which are as under: Sl. No. Date of investment Nature of investment (Note 4) Nature of income (Note 5) Amount of income on investment during the year Details of the entity in which Investment made Date of sale Nature of entity (Note 6) Name PAN (1) (2) (3) (4) (5) (6) (7) (8) (9) 1. 2. Total 8. The SWF satisfies all the conditions required for the purposes of exemption under clause (23FE) of section 10 of the Act, that is, - (a) Whether the Government of foreign country wholly owns and contro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... including the right to appoint directors or executive director Yes/No (j) If answer to (i) is yes, then provide the following details: i. Name of such investee ii. PAN of the investee iii. Amount of investment in such investee at the end of the year (k) Whether it has complied with the requirement of intimation of the details of investment made by it in India in Form No II issued vide circular No 15/2020 dated 22.07.2020 Yes/No (l) Whether it has loans or borrowings, as defined in sub-clause(a) of clause (ii) Explanation 2 to clause (23FE) of section 10 of the Act, directly or indirectly, for the purposes of making investment in India Yes/No (m) If answer to (l) is yes, then provide the following details: (i) Name of the person from whom s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... referred to in item (b) of sub-clause (iii) of clause (23FE) of section 10 of the Act 2 Alternative Investment Fund referred to in item (c) of sub-clause (iii) of clause (23FE) of section 10 of the Act 3 Domestic company referred to in item (d) of sub-clause (iii) of clause (23FE) of section 10 of the Act 4 Infrastructure Finance Company/Infrastructure Debt Fund-NBFC referred to in item (e) of sub-clause (iii) of clause (23FE) of section 10 of the Act 5 [F. No. 500/SWF5/S10(23FE)/FT TR-II(Pt.2)] APOORV TIWARI, Under Secy. **************** NOTES:- 1. Substituted vide Notification No. 84/2024 dated 18-07-2024 before it was read as, 31st day of March, 2024 - Notification Tax Management India - taxmanagementindia - taxmanagement - taxmanage ..... X X X X Extracts X X X X X X X X Extracts X X X X
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