Exemption for sovereign wealth and pension funds: investment linked tax relief conditioned on holding, thresholds, and reporting. Exemption for specified persons on dividend, interest and long term capital gains from infrastructure investments is subject to a three year holding period, minimum investment thresholds for intermediate vehicles, and prescribed proportional computation of exempt income. Transfers in breach of the holding period or other essential conditions cause withdrawal of exemption for the year of breach and taxability of previously exempt amounts in that year. Hybrid entities require separate books and proportionate allocation of exempt income. Downstream transfers trigger capital gain computation using fair market value on the date of each downstream transfer, and audit and quarterly reporting may be limited to Indian investments where accounts are segmented.