Non Banking Financial Company classification ties tax treatment to Top, Upper and Middle layer designations under RBI framework. A Non Banking Financial Company is defined as a company that is a financial institution, whose principal business is receiving deposits or lending, or other non banking institutions as specified by the Bank with Central Government approval. A Central Government notification applies the RBI's layered classification-Top Layer, Upper Layer and Middle Layer-to determine the classes of NBFCs relevant for specified Income tax provisions, tying tax treatment to the RBI framework and setting the notification's operative date.