The CBDT vide Notification No. 13/2025 dated February 07, 2025, notifies the Income-tax (Third Amendment) Rules, 2025, amending the Income-tax Rules, 1962. These rules will come into force upon publication in the Official Gazette. The amendments primarily pertain to the Infrastructure Debt Fund (IDF), which must be established as a Non-Banking Financial Company (NBFC) in compliance with the Reserve Bank of India’s regulatory framework. The IDF’s funds can only be invested in infrastructure projects that have been operational for at least one year or toll-operate-transfer projects as direct lenders. The IDF is permitted to issue rupee or foreign currency bonds, zero coupon bonds, or raise funds through external commercial borrowings, all subject to specific regulations. External commercial borrowings must have a minimum tenor of five years and cannot be sourced from foreign branches of Indian banks. Additionally, the IDF is prohibited from investing in projects where its specified shareholders or associated enterprises have a substantial interest. The notification also includes minor textual amendments, such as substituting “associate” with “associated” and redefining “specified shareholder” to include entities holding at least 30% of the voting power in the IDF.
The Complete Notification can be accessed at: https://a2ztaxcorp.net/wp-content/uploads/2025/02/CBDT-_-Income-tax-Third-Amendment-Rules-2025.pdf
