INCOME NOT TO BE INCLUDED IN TOTAL INCOME OF CERTAIN ELIGIBLE PERSONS INCLUDING INVESTMENT FUNDS, BUSINESS TRUSTS AND THEIR UNIT HOLDERS

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.... income chargeable under the head "Profits and gains of business or profession". A unit holder of an investment fund. Nil. 3. Any income by way of- (a)interest received or receivable from a special purpose vehicle; or (b)dividend received or receivable from a special purpose vehicle. A business trust. Nil. 4. Any income by way of renting or leasing or letting out any real estate asset owned directly by such business trust. A business trust, being a real estate investment trust. Nil. 5. Any distributed income referred to in section 223. Any unit holder of a business trust. Exemption shall not be allowed on that proportion of the income which is of the same nature as-- (a) interest received or receivable from a special purpose vehicle by the business trust; or (b) dividend received or receivable from a special purpose vehicle by the business trust (in a case where the special purpose vehicle has exercised the option under section 200); or (c) income of a business trust, being a real estate investment trust, by way of renting or leasing or letting out any real estate asset owned directly by such business trust.....

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....mestic company has investment of less than 100% in one or more of the eligible infrastructure entity, income accrued or arisen or received or attributable to such investments, directly or indirectly, which is exempt herein shall be calculated proportionately to the investment made in one or more of the eligible infrastructure entity, in such manner, as may be prescribed; (g) where an eligible Non-Banking Financial Company has lending of less than 100% in one or more of the eligible infrastructure entity, income accrued or arisen or received or attributable to such lending, directly or indirectly, which is exempt herein shall be calculated proportionately to the lending made in eligible infrastructure entity, in such manner, as may be prescribed; (h) in case a sovereign wealth fund or pension fund has loans or borrowings, directly or indirectly, for the purposes of making investment in India, such fund shall be deemed to be not eligible for exclusion from total income. 8. Any income falling under section 10(23F) and (23FA) of the Income-tax Act, 1961 (43 of 1961), subject to the conditions as specified therein.     Note 1.-For the purposes of Sl. Nos. ....

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...., which- (A) has been granted a certificate of registration, before the 21^st May, 2012, as a Venture Capital Fund and is regulated under the Venture Capital Funds Regulations; or (B) has been granted a certificate of registration as Venture Capital Fund as a sub-category of Category I Alternative Investment Fund under the Alternative Investment Funds Regulations or as referred ^1[to in regulation] 18(2) of the International Financial Services Centres Authority (Fund Management) Regulations, 2022 made under the International Financial Services Centres Authority Act, 2019 (50 of 2019), and which fulfils the following conditions:- (I) it has invested not less than two-thirds of its investible funds in unlisted equity shares or equity linked instruments of venture capital undertaking; (II) it has not invested in any venture capital undertaking in which its trustee or the settler holds, either individually or collectively, equity shares in excess of 15% of the paid-up equity share capital of such venture capital undertaking; (III) the units, if any, issued by it are not listed in any recognised stock exchange; and (IV) any othe....

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.... (B) is not liable to tax in such foreign country or if liable to tax, exemption from taxation for all its income has been provided by such foreign country; (C) does not participate in the day-to-day operations of investee but the monitoring mechanism to protect the investment with the investee including the right to appoint directors or executive director shall not be considered as participation in day-to-day operations of the investee; (D) is specified by the Central Government, by notification for this purpose and fulfils conditions specified in such notification; and (E)satisfies such other conditions as may be prescribed; (iv) the Public Investment Fund of the Government of the Kingdom of Saudi Arabia; (v) a wholly owned subsidiary of the Public Investment Fund of the Government of the Kingdom of Saudi Arabia, which-- (A) is a resident of Saudi Arabia; and (B) makes investment, directly or indirectly, out of the fund owned by such Government; (b) "investee" means a business trust or eligible infrastructure entity or eligible Alternate Investment Fund or eligible domestic company or eligible Non-Banking....