Specified person designation under clause 23FE conditions tax exemption on Indian investments subject to strict compliance and reporting. Designation of CDPQ Fixed Income XI Inc. as a specified person under clause (23FE) of section 10 conditions tax exemption on eligible Indian investments upon fulfilment of specific requirements: timely income-tax return filing, Form No. 10BBC accountant certification, quarterly Form No. 10BBB investment intimations, segmented accounting for qualifying investments, continued regulation under Que bec law, use of earnings and assets solely for statutory obligations and defined contributions, limits on non-core asset use with vesting to the Government of Que bec, prohibition on borrowings for Indian investments, and restriction on day-to-day participation in investees; breach renders exemption unavailable.
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.
Specified person designation under clause 23FE conditions tax exemption on Indian investments subject to strict compliance and reporting.
Designation of CDPQ Fixed Income XI Inc. as a specified person under clause (23FE) of section 10 conditions tax exemption on eligible Indian investments upon fulfilment of specific requirements: timely income-tax return filing, Form No. 10BBC accountant certification, quarterly Form No. 10BBB investment intimations, segmented accounting for qualifying investments, continued regulation under Que bec law, use of earnings and assets solely for statutory obligations and defined contributions, limits on non-core asset use with vesting to the Government of Que bec, prohibition on borrowings for Indian investments, and restriction on day-to-day participation in investees; breach renders exemption unavailable.
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