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

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..... 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 from investment in infrastructure in .....

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..... r 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 clause, the Board may, with the approval of .....

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..... ny 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 under the said clause, provided that the source of the in .....

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