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The Central Government specifies Stretford Investment Pte. Ltd. as a specified person for tax exemption under section 10 clause 23FE. The fund makes investments in India on or after the publication date and on or before March 31, 2024. The fund files income tax returns for all relevant previous years. The fund audits books of account and furnishes an audit report. The fund submits quarterly statements electronically in Form II. The fund maintains a segmented account of income and expenditure. The Government of Singapore owns and controls the fund directly or indirectly. The fund does not take loans for making investments in India. The fund does not participate in day-to-day operations of investees.
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MINISTRY OF FINANCE (Department of Revenue) (CENTRAL BOARD OF DIRECT TAXES) NOTIFICATION
New Delhi, the 5th May 2021 (INCOME-TAX)
S.O. 1762(E).—In exercise of the powers conferred by sub-clause (vi) of clause (b) of the Explanation 1 to clause (23FE) of section 10 of the Income-tax Act, 1961 (43 of 1961) (hereinafter referred to as the “Act”), the Central Government hereby specifies the sovereign wealth fund, namely, the Stretford Investment Pte. Ltd., (hereinafter referred to as “the assessee”) as the specified person for the purposes of the said clause in respect of the investment made by it in India on or after the date of publication of this notification in the Official Gazette but on or before the 31st day of March, 2024 (hereinafter referred to as “said investments”) subject to the fulfilment of the following conditions, namely:-
Violation of any of the conditions as stipulated in the clause (23FE) of Section 10 of the Act and this notification shall render the assessee ineligible for the tax exemption.
This notification shall come into force from the date of its publication in the Official Gazette.
ANNEXURE
Audit report to be filed by the Sovereign Wealth Fund claiming exemption under clause (23FE) of section 10 of the Income-tax Act, 1961
Part I
*I/we report that the statutory audit of M/s. ………...........…………………. (Name and address of the assessee with Permanent Account Number or Aadhaar Number), the particulars of which are given in Part II was conducted by *me/ us/ M/s. …………………………………………..………. as per the requirement under the Notification No …../…… dated ……… published in the Official Gazette on ……....
2.1 *The conditions not complied with by the assessee are as under:-
Part II
Name of the Assessee :
PAN/ AADHAAR :
Previous Year :
Total Income of the Assessee during the previous year :
Total amount of income eligible for exemption under clause (23FE) of section 10 of the Income-tax Act, 1961 (as per details in column 11 of table at item no.6) :
The opening balance (i.e. the closing balance as on the last date of the preceding financial year) of the investment made which is eligible for exemption under clause (23FE) of section 10 is ______________(in rupees) and details of the investment by the Sovereign Wealth Fund (SWF) during the period are as under:
| Sl. No. | Date of investment | Amount of investment | Nature of investment (Instruction 4) | Nature of income (instruction 5) | Amount of income on investment during the year | Details of the entity in which Investment made | Amount of income which is eligible for exemption under clause (23FE) of section 10 (Attach calculation sheet as per relevant rules) | |||
|---|---|---|---|---|---|---|---|---|---|---|
| Nature of entity (instruction 6) | Name | PAN | In case if nature of entity code is 3/4/5, whether the entity has made minimum investment of 50 or75 or 90 percent as required in item (c) or (d) or (e) of sub-clause (iii) of clause (23FE) of section 10 (Attach calculation sheet as per relevant rules) | |||||||
| (1) | (2) | (3) | (4) | (5) | (6) | (7) | (8) | (9) | (10) | (11) |
| 1. | ||||||||||
| 2. | ||||||||||
| Total | ||||||||||
