CBDT extends eligible period of investment under section 10(23FE)

CBDT extends eligible period of investment under section 10(23FE) in view of the provisions of the Finance Act 2025

CBDT vide Circular No. 9/2022 dated 09.05.2022 prescribed guidelines under clause (23FE) of section 10 of the Income-tax Act, 1961 (the Act). The section 10(23FE) provides exemption to wholly owned subsidiaries of Abu Dhabi Investment Authority (ADIA), sovereign wealth funds (SWF) and pension funds (PF) on their specified income arising from investment made in infrastructure in India.

As per said Circular, the exemption was available for investment made in infrastructure in India, during the period beginning with 01.04.2020 and ending on 31.03.2024 subject to fulfilment of certain conditions.

Recently enacted Finance Act 2025 amended clause (23FE) of section 10 so as to extend the date of investment under the said clause from 31st day of March, 2025 to 31st day of March, 2030. The said amendment is effective from the pt day of April, 2025

In view of the above, reference to the date 31.03.2024 in the opening para and to the date 31st March, 2024 in paras 4.6.2 and 4.6.3 of the said circular, shall be read as 31st March, 2030 with effect from the 1st day of April, 2025.

Download CBDT Circular No. 11/2025 Click Here >>

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