Sovereign wealth fund exemption specified, subject to ownership, reporting, audit and non borrowing compliance conditions. Specification of Seventy Second Investment Company LLC as a specified person for exemption under the Income tax Act is conditional on ten requirements including continued Government of Abu Dhabi ownership and control, regulation under UAE/Abu Dhabi law, earnings credited to the Abu Dhabi government, prohibition on using loans or borrowings to make investments in India, vesting of assets in that government on dissolution, non participation in investee day to day operations, and compliance with filing, audit, quarterly reporting and segmented account maintenance; breach renders the fund ineligible.
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Provisions expressly mentioned in the judgment/order text.
Sovereign wealth fund exemption specified, subject to ownership, reporting, audit and non borrowing compliance conditions.
Specification of Seventy Second Investment Company LLC as a specified person for exemption under the Income tax Act is conditional on ten requirements including continued Government of Abu Dhabi ownership and control, regulation under UAE/Abu Dhabi law, earnings credited to the Abu Dhabi government, prohibition on using loans or borrowings to make investments in India, vesting of assets in that government on dissolution, non participation in investee day to day operations, and compliance with filing, audit, quarterly reporting and segmented account maintenance; breach renders the fund ineligible.
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