TaxTMI 
TaxTMI 
Central Government specifies the sovereign wealth fund, namely, Seventy Second Investment Company LLC
X X X X Extracts X X X X
X X X X Extracts X X X X
....r the purposes of the said clause in respect of the investment made by it in India on or after the date of publication of this notification in the Official Gazette but on or before the 1[31st day of March, 2025] (hereinafter referred to as "said investments") subject to the fulfilment of the following conditions, namely:- (i) the assessee shall file return of income, for all the relevant previous years falling within the period beginning from the date in which the said investment has been made and ending on the date on which such investment is liquidated, on or before the due date specified for furnishing the return of income under sub-section (1) of section 139 of the Act; (ii) the assessee shall get its books of account audited for th....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ted by that Government so that no portion of the earnings inures any benefit to any private person, barring any payment made to creditors or depositors for loan taken or borrowing [as defined in sub-clause (a) of clause (ii) of Explanation 2 to clause (23FE) of section 10 of the Act] made for purposes other than for making investment in India; (viii) the assessee shall not have any loan or borrowing [as defined in sub-clause (a) of clause (ii) of Explanation 2 to clause (23FE) of section 10 of the Act], directly or indirectly, for the purposes of making investment in India; (ix) the asset of the assessee shall vest in the Government of Abu Dhabi upon dissolution, barring any payment made to creditors or depositors for loan taken or borr....
X X X X Extracts X X X X
X X X X Extracts X X X X
..... 2. In *my/ our opinion and to the best of *my/ our information and according to examination of books of account including other relevant documents and explanations given to*me/us, it is certified that the assessee *has/ has not complied with the conditions as laid down under clause (23FE) of section 10 of the Income-tax Act, 1961 and those provided in the said notification specifying the assessee being the Sovereign Wealth Fund as specified person for the purposes of claiming exemption under the said clause (23FE). 2.1 *The conditions not complied with by the assessee are as under:- (a) …………………………….…………………&helli....
X X X X Extracts X X X X
X X X X Extracts X X X X
....-tax Act, 1961 (as per details in column 11 of table at item no.6) : 6. The opening balance (i.e. the closing balance as on the last date of the preceding financial year) of the investment made which is eligible for exemption under clause (23FE) of section 10 is _____________(in rupees) and details of the investment by the Sovereign Wealth Fund (SWF) during the period are as under: Sl. No. Date of Inves-tment Amount of invest-men Nature of investment (Instruction 4) Nature of income (Instru-ction 5) Amount of income on investment during the year Details of the entity in which Investment made Amount of income which is eligible for exemption under clause (23FE) of section 10 (Attach calcu....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ectly Yes/No (b) Mention the name of the Government of foreign country which owns and controls the SWF, directly or indirectly (c) Whether the Government of foreign country owns and controls the SWF, directly or indirectly Directly/ Indirectly (d) If the Government of foreign country owns and controls the SWF indirectly, give details of the chain of ownership (e) Name of the law(s) under which the SWF is set up and regulated (f) Whether the earnings of the said fund are credited either to the account of the Government of that foreign country or to any other account designated by that Government so that no portion of the earnings inures any benefit to any private person, barring any payment made to creditors or depositors for loa....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... loan or borrowing has been taken (ii) Amount of loan or borrowing at the beginning of the year (iii) Amount of loan or borrowing received during the year (iv) Amount of loan or borrowing repaid during the year (v) Amount of loan or borrowing at the end of the year (n) Whether separate segmented account is maintained for income and investment in respect of investment which qualifies for exemption under clause (23FE) of section 10 of the Act Yes/No Place: …………… Date: …………… **(Signature and stamp/ Seal of the signatory) Name of the signatory ………………… Full address ………………&hel....