Chapter XII-DA - SPECIAL PROVISIONS RELATING TO TAX ON DISTRIBUTED INCOME OF DOMESTIC COMPANY FOR BUY-BACK OF SHARES (From Section 115QA to Section 115QC)
Part C - Procedure for filing of return in respect of fringe benefits, assessment and payment of tax in respect thereof (From Section 115WD to Section 115WM)
Chapter XX-B - REQUIREMENT AS TO MODE OF ACCEPTANCE, PAYMENT OR REPAYMENT IN CERTAIN CASES TO COUNTERACT EVASION OF TAX (From Section 269SS to Section 269TT)
Fund management activity by eligible fund managers does not create business connection in India for qualifying foreign funds. Section 9A excludes fund management activity by an eligible fund manager from constituting a business connection in India for an eligible investment fund established abroad, provided the fund meets non residence, treaty or notified jurisdiction, resident participation limits, investor protection, membership and concentration limits, corpus and remuneration criteria. The eligible fund manager must be independent, registered under specified regulations, act in the ordinary course of business, and together with connected persons not exceed profit participation limits. The fund must file an annual compliance statement; the section preserves taxation of income otherwise includible and permits regulatory modifications.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Fund management activity by eligible fund managers does not create business connection in India for qualifying foreign funds.
Section 9A excludes fund management activity by an eligible fund manager from constituting a business connection in India for an eligible investment fund established abroad, provided the fund meets non residence, treaty or notified jurisdiction, resident participation limits, investor protection, membership and concentration limits, corpus and remuneration criteria. The eligible fund manager must be independent, registered under specified regulations, act in the ordinary course of business, and together with connected persons not exceed profit participation limits. The fund must file an annual compliance statement; the section preserves taxation of income otherwise includible and permits regulatory modifications.
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