Business connection exclusion for offshore funds depends on fund eligibility, independent regulated management, restricted Indian activities, and annual compliance reporting.

Business connection exclusion under section 9(12) is available to qualifying offshore investment funds that satisfy residence, Indian-participation, operational and reporting conditions. The fund must not conduct, control or manage business in India, and activities creating a business connection may be undertaken only by an eligible fund manager. The manager must be registered, independent of the fund, act in the ordinary course of fund management, and have restricted profit entitlement. Funds must file prescribed compliance information within 90 days after the tax year ends.

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