TaxTMI 
TaxTMI 
Income of a specified person - Sovereign wealth fund i.e. Public Investment Fund Notified for the purposes of the said clause in respect of the investment made by it in India.
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....er referred to as "the assessee") as the specified person for 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 2[31st day of March, 2030] (hereinafter referred to as "the 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 on 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; ....
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....ngdom of Saudi Arabia 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 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 Explanation2 to clause (23FE) of section 10 of the Act], directly or indirectly, for the purposes of making investment in India; (ix) the assets of the assessee shall vest in the Government of the Kingdom of Saudi Arabia upon dissolution, bar....
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.... in the Official Gazette on .......... 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 (hereinafter referred to as the "Act") and those provided in the said notification specifying the assessee being the Sovereign Wealth Fund (hereinafter referred to as the "SWF") as specified person for the purposes of claiming exemption under the said clause (23FE) of the Act. 2.1 *The conditions not complied with by the assessee are as under:- (a) .............................
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....e entity in which Investment made Amount of income which is eligible for exemption under clause (23FE) of section 10 of the Act (Attach calculation sheet as per the relevant rules) Nature of entity (Note 6) Name PAN In case nature of entity code is 3/4/5, whether the entity has made minimum investment of 50 or 75 or 90 percent as required in item (c) or (d) or (e) of sub-clause (iii) of clause (23FE) of section 10 of the Act (Attach calculation sheet as per the relevant rules) (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) 1. 2.  ....
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....ction 10 of the Act, that is, - (a) Whether the Government of foreign country wholly owns and controls the SWF, directly or indirectly 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 designate....
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.... the Act, directly or indirectly, for the purposes of making investment in India Yes/No (m) If answer to (l) is yes, then provide the following details: (i) Name of the person from whom such 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 ....