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of <h1>Non-resident investors' offshore income via AIFs not taxable in India u/s 115UB, Income-tax Act, 1961.</h1> The circular clarifies the taxability of income earned by non-resident investors from offshore investments through Alternate Investment Funds (AIFs). According to Section 115UB of the Income-tax Act, 1961, income from investments made by Category I or II AIFs is treated as if made directly by the investor. Consequently, income from offshore investments routed through these AIFs is not taxable in India for non-resident investors under Section 5(2). Additionally, any losses from such investments, being exempt, cannot be set off or carried forward against the income of the AIFs.
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