Exemption eligibility for sovereign and pension funds clarified: borrowing for investments disqualifies, general borrowings do not. The Board clarifies that a specified fund (or any group concern) that has taken loans or borrowings specifically for the purpose of making investment in India shall not be eligible for the exemption. If loans or borrowings were not taken specifically for making the investment in India, it shall not be presumed that the investment was made out of such borrowings and the specified fund remains eligible for the exemption, subject to fulfilment of all other conditions and provided the source of the investment is not from those borrowings.
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.
Exemption eligibility for sovereign and pension funds clarified: borrowing for investments disqualifies, general borrowings do not.
The Board clarifies that a specified fund (or any group concern) that has taken loans or borrowings specifically for the purpose of making investment in India shall not be eligible for the exemption. If loans or borrowings were not taken specifically for making the investment in India, it shall not be presumed that the investment was made out of such borrowings and the specified fund remains eligible for the exemption, subject to fulfilment of all other conditions and provided the source of the investment is not from those borrowings.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
