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The Central Government specifies the sovereign wealth fund Seventy Second Investment Company LLC as the specified person for tax exemption under section 10 clause 23FE. The fund qualifies for investments made in India from the publication date until 2024-03-31. The fund must file income tax returns and audit reports, maintain segmented accounts, and submit quarterly statements. The fund must remain owned and controlled by the Government of Abu Dhabi and must not have loans for Indian investments or 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 27th June, 2022 (INCOME-TAX)
S.O. 2910(E).—In exercise of 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, Seventy Second Investment Company LLC (PAN: ABICS2676N), (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 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 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 :
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) | In case nature of entity code is 3/4/5, whether the entity has made minimum investment of 50 or 75 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) | ||
|---|---|---|---|---|---|---|---|---|---|---|
| Nature of entity (instruction 6) | Name | PAN | ||||||||
| (1) | (2) | (3) | (4) | (5) | (6) | (7) | (8) | (9) | (10) | (11) |
| 1. | ||||||||||
| 2. | ||||||||||
| Total | ||||||||||
