Income of a specified person arising from an investment made by it in India - Pension fund, namely, 2589555 Ontario Limited specified. - 114/2022 - Income Tax Act, 1961
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Tax exemption for specified pension funds subject to compliance, reporting, governance, and borrowing restrictions for India investments. The Central Government specifies 2589555 Ontario Limited as a specified person eligible for exemption under clause (23FE) for investments in India, subject to conditions: timely filing of income-tax returns, furnishing Form No. 10BBC, quarterly intimations in Form No. 10BBB, maintaining segmented accounts, remaining regulated under Ontario law, administering assets only to meet statutory obligations and defined contributions for beneficiaries, prohibition on borrowings for making investments in India, restriction on day-to-day participation in investees, and preservation of assets and earnings solely for participants or beneficiaries; breach voids eligibility.
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Provisions expressly mentioned in the judgment/order text.
Tax exemption for specified pension funds subject to compliance, reporting, governance, and borrowing restrictions for India investments.
The Central Government specifies 2589555 Ontario Limited as a specified person eligible for exemption under clause (23FE) for investments in India, subject to conditions: timely filing of income-tax returns, furnishing Form No. 10BBC, quarterly intimations in Form No. 10BBB, maintaining segmented accounts, remaining regulated under Ontario law, administering assets only to meet statutory obligations and defined contributions for beneficiaries, prohibition on borrowings for making investments in India, restriction on day-to-day participation in investees, and preservation of assets and earnings solely for participants or beneficiaries; breach voids eligibility.
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