The Central Board of Direct Taxes (CBDT), Department of Revenue, Ministry of Finance, has notified the Core Settlement Guarantee Fund (PAN: AAAJN1263G) set up by the National Commodity Clearing Limited (NCCL), a recognised clearing corporation, for the purposes of the relevant exemption provision under the Income-tax Act, 2025.
The notification has been issued vide Notification No. 79/2026, dated July 07, 2026, in exercise of the powers conferred by Schedule III [Table: Sl. No. 30] read with section 11 of the Income-tax Act, 2025.
Under the notification, the Core Settlement Guarantee Fund established by NCCL has been notified for Tax Year 2026-27 onwards, subject to fulfilment of the conditions prescribed by the Central Government.
As a key condition of the notification, the National Commodity Clearing Limited shall continue to be recognised as a clearing corporation by the Securities and Exchange Board of India (SEBI) in terms of Note 11 to Schedule III of the Income-tax Act, 2025.
The notification further provides that where any amount standing to the credit of the Core Settlement Guarantee Fund, and not charged to income-tax during any tax year, is shared wholly or partly with a specified person, the amount so shared shall be deemed to be the income of the tax year in which such sharing takes place and shall accordingly be chargeable to income-tax.
The Core Settlement Guarantee Fund is also required to furnish its return of income in accordance with section 263 of the Income-tax Act, 2025.
The CBDT has clarified that failure to comply with any of the prescribed conditions shall result in withdrawal of the exemption available under Schedule III [Table: Sl. No. 30] read with section 11 of the Income-tax Act, 2025, along with initiation of proceedings under the said Act.
The notification provides statutory certainty regarding the tax treatment of the Core Settlement Guarantee Fund of NCCL, while linking the exemption to continued regulatory recognition and compliance with the reporting and taxation conditions prescribed under the Income-tax Act, 2025.
The Notification can be accessed at: https://www.incometaxindia.gov.in/documents/d/guest/notification-79-2026-pdf
