The Central Board of Direct Taxes (CBDT) has issued Circular No. 11/2025 dated September 02, 2025, modifying its earlier Circular No. 9/2022 dated 9th May 2022, which provided guidelines under clause (23FE) of section 10 of the Income-tax Act, 1961.
Key Highlights
- The Finance Act, 2025 has amended clause (23FE) of section 10 of the Income-tax Act.
- The date of making investments eligible for exemption under the said clause has been extended from 31st March 2024 to 31st March 2030.
- The amendment takes effect from 1st April 2025.
Accordingly, all references to 31.03.2024 in Circular No. 9/2022, including in its opening paragraph and paras 4.6.2 and 4.6.3, shall now be read as 31.03.2030.
Objective
This extension has been introduced to:
- Encourage long-term infrastructure investments in India.
- Provide additional time for Sovereign Wealth Funds (SWFs), Pension Funds (PFs), and other specified entities to channel investments into the Indian infrastructure sector.
- Strengthen the government’s commitment to building a robust infrastructure ecosystem by attracting global capital.
Background
- Clause (23FE) of section 10 provides income-tax exemption to specified persons (SWFs, PFs, ADIA subsidiaries, etc.) on income in the nature of dividend, interest, and long-term capital gains arising from investments in infrastructure entities in India.
- The timeline for such investments, earlier ending on 31st March 2024, has now been extended by five years to 31st March 2030.
The Circular can be accessed at: https://a2ztaxcorp.net/wp-content/uploads/2025/09/Circular-11-2025.pdf
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