Just a moment...

Top
Help
×

By creating an account you can:

Logo TaxTMI
Call Us / Help / Feedback

Contact Us At :

E-mail: [email protected]

Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters0/2000
Make Most of Text Search
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
  6. Text Search
  7. The system will try to fetch results that contains ALL your words.
  8. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
  9. Text Search
Add to...
You have not created any category. Kindly create one to bookmark this item!
Create New Category
Hide
Title :
Description :
❮❮ Hide
Default View
Expand ❯❯
Close ✕
🔎 TMI Notes - Adv. Search
TEXT SEARCH:

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In:
Main Text + AI Text
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws----
  • ---- All Laws----
  • Benami Property
  • Bill
  • Central Excise
  • Companies Law
  • Customs
  • DGFT
  • FEMA
  • GST
  • GST - States
  • IBC
  • Income Tax
  • Indian Laws
  • Money Laundering
  • SEBI
  • SEZ
  • Service Tax
  • VAT / Sales Tax
Types:
---- All Types ----
  • ---- All Types ----
  • Act Rules
  • Case Laws
  • Circulars
  • Manuals
  • News
  • Notifications
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
RelevanceDefaultDate
    Comprehensive regime for the taxation of "specified income" of registered non-profit organisations (...
    Special Taxation of Non-Resident Sportsmen and Entertainers : Clause 211 of the Income Tax Bill, 202...
    Special Tax Regimes for Gaming and Gambling Incomes : Clause 194 (Table: S. No. 1) of Income Tax Bil...
    Special concessional tax regime for new manufacturing co-operative societies in India : Clause 204 o...
    Concessional tax regime for resident cooperative societies in India : Clause 203 of the Income Tax B...
    Introducing a new tax regime with revised tax slabs and by eliminating various exemptions and deduct...
    Concessional tax regime for new manufacturing domestic companies : Clause 201 of the Income Tax Bill...
    Optional Concessional Taxation for domestic Companies : Clause 200 of the Income Tax Bill, 2025 Vs. ...
    Concessional Taxation for Manufacturing Domestic Companies : Clause 199 of Income Tax Bill, 2025 Vs....
    Taxation of Special Incomes in India "Profits and gains from Life Insurance Business" : Clause 194 o...
    Evolving the Taxation of Foreign Portfolio Investment : Clause 210 of the Income Tax Bill, 2025 Vs. ...
    Taxation of income from Global Depository Receipts (GDRs) earned by resident employees of Indian com...
    Legislative framework governing the taxation of income derived by non-residents from bonds and Globa...
    Evolution of Special Tax Regimes for Offshore Funds : Clause 208 of the Income Tax Bill, 2025 Vs. Se...
    Tax treatment of the accumulated balance of recognised provident funds (RPFs) : Clause 191 of the In...
    Streamline, simplify, and update the tax framework applicable to non-residents and foreign companies...
    Special procedure for calculating tax liability on income discovered during search operations : Clau...
    Recalibrating Long-Term Capital Gains Taxation : Clause 198 of the Income Tax Bill, 2025 Vs. Section...
    Reforming Long-Term Capital Gains Taxation : Clause 197 of the Income Tax Bill, 2025 Vs. Section 112...
    taxation of short-term capital gains (STCG) : Clause 196 of the Income Tax Bill, 2025 Vs. Section 11...
❯❯
MaximizeMaximizeMaximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

    +

    Are you sure you want to delete "My most important" ?

    NOTE:

    Notes
    Showing Results for :
    Reset Filters
    Results Found:
    Show All SummariesHide All Summaries
    Act RulesBills
    Show AI Summary
    Anonymous donations taxation: broader scope and threshold rule increase compliance and record-keeping obligations for non-profits.
    Clause 337 targets anonymous donations to registered non-profit organisations (excluding entities wholly for religious purposes) by taxing the amount of anonymous donations exceeding the higher of a specified absolute sum or a percentage of such donations in the tax year, with contemporaneous recognition of receipts. The clause broadens applicability beyond the prior enumerated institutions, omits a specified tax rate, and lacks detailed definitions and compliance mechanics, creating interpretive and administrative uncertainties for mixed purpose organisations and cross border receipts.
    Act RulesBills
    Show AI Summary
    Special taxation of non-resident sports and entertainment income: flat-rate treatment with no deductions and TDS-driven compliance.
    A flat-rate regime taxes specified India-sourced receipts of non-resident sportsmen, sports associations, and entertainers-covering participation, performances, advertisements and article contributions-with such receipts treated as ring-fenced special income taxed separately from other income; deductions are expressly disallowed for computing that special income, and proper withholding at source can exempt a taxpayer from domestic return-filing when that is the taxpayer's sole Indian income.
    Act RulesBills
    Show AI Summary
    Tax on gambling winnings: flat gross tax with no deductions, and online gaming treated separately.
    Clause 194 (Table S. No. 1) taxes winnings from lotteries, crossword puzzles, races (excluding income from owning or maintaining race horses), card games and other gambling at a flat rate on gross receipts with no deductions or set-off; tax is computed in two steps-tax on such winnings and tax on the balance of income as if winnings were excluded-and winnings from online games are expressly excluded and dealt with separately.
    Act RulesBills
    Show AI Summary
    Concessional tax regime for new manufacturing co-operative societies offers reduced tax for qualifying manufacturing income.
    A concessional tax regime grants newly formed manufacturing co-operative societies an optional, irrevocable reduced tax treatment for qualifying manufacturing income, contingent on formation and commencement within prescribed windows, exercise of the option in the prescribed manner, and compliance with anti abuse conditions. Qualifying income is computed without specified deductions or set offs, certain non manufacturing income and specified gains are taxed at higher rates, and failure to satisfy conditions withdraws the regime for the relevant and subsequent years.
    Act RulesBills
    Show AI Summary
    Concessional tax regime for resident cooperative societies: elective simplified computation in exchange for forgoing specified deductions.
    Clause 203 establishes an elective concessional tax regime for resident cooperative societies permitting computation of total income without specified deductions and without set-off of losses or depreciation attributable to those disallowed deductions; the option is exercised in the prescribed manner within the return-filing timeframe, is irrevocable, and failure to meet conditions renders the option invalid for that and subsequent years, while losses and depreciation not allowed are deemed finally given effect. An IFSC carve-out permits designated deductions for IFSC units subject to conditions.
    Act RulesBills
    Show AI Summary
    New tax regime narrows exemptions and denies related loss carry-forwards, requiring strict opt-in procedures and electronic compliance.
    Clause 202 creates a consolidated new tax regime for individuals, HUFs, AOPs, BOIs and certain artificial juridical persons pairing a graded slab structure with the denial of most specified exemptions, deductions and loss set-offs. Total income is computed without the benefit of listed deductions and without carry-forward or set-off of losses and depreciation attributable to those disallowed items. The clause prescribes an option procedure with strict withdrawal and re-entry limits for business/professional assessees and contemplates procedural electronic filing requirements and an IFSC carve-out.
    Act RulesBills
    Show AI Summary
    Concessional tax regime for new manufacturing companies limits exemptions and binds firms to an irrevocable option for preferential taxation.
    Concessional tax regime for new manufacturing domestic companies grants a lower corporate rate to qualifying manufacturers while disallowing most exemptions and deductions. The regime requires an irrevocable option, exercised in the prescribed manner by the due date for the first return; failure to meet conditions causes permanent loss of eligibility. Income computation is exemption free, with no carry forward for losses or depreciation attributable to disallowed deductions. Benefits can continue on amalgamation if conditions are met. Procedural and definitional details are expected to be specified in subordinate rules.
    Act RulesBills
    Show AI Summary
    Optional concessional corporate tax regime requires companies to forgo specified deductions and accept irrevocable tax treatment.
    Optional concessional corporate tax regime requires domestic companies to compute taxable income without specified deductions and to forgo set-off or carry forward of losses or depreciation attributable to those disallowed items, treating such losses and depreciation as having been given full effect; the option must be exercised in the prescribed manner by the filing due date, is irrevocable and applies to subsequent tax years, with modified treatment for IFSC units and procedural details to be provided by subordinate rules.
    Act RulesBills
    Show AI Summary
    Concessional tax regime for manufacturing companies requires irrevocable option and prohibits set off of attributable losses.
    Clause 199 creates a concessional tax regime for qualifying domestic manufacturing companies, available at the taxpayer's option, conditioned on exclusive engagement in manufacturing related activities and computed without specified deductions. It precludes set off of losses attributable to those disallowed deductions by deeming such losses to have been fully given effect to. The option must be exercised in the prescribed manner by the due date for the first return and, once exercised, is irrevocable for subsequent years except where a statutory switch is permitted, thereby trading lower tax rates for forfeiture of targeted incentives and necessitating clear procedural compliance.
    Act RulesBills
    Show AI Summary
    Taxation of special incomes: consolidated flat-rate regime covering life insurance profits and emerging digital income streams.
    Clause 194 creates a consolidated flat-tax framework for specified special incomes-winnings, patent royalties, carbon credits, VDAs, online game winnings, and life insurance profits-providing category-specific rates, comprehensive definitions, and an overriding application. For life insurance business it preserves a concessional 12.5% flat tax and the aggregate computation method but omits the prior temporary deposit requirement and lacks detailed computation rules, potentially causing interpretive issues on measuring ''profits and gains.'' Clause 194 modernises taxation of emerging income streams while centralising special-income treatment under one provision.
    Act RulesBills
    Show AI Summary
    Taxation of foreign portfolio investment: concessional rates tied to strict attribution and compliance requirements.
    Clause 210 creates a consolidated tax framework for FIIs and specified funds on securities income and capital gains, setting concessional rates by income category and conditioning those rates on prescribed attribution to non resident unit holders (excluding permanent establishments). It restricts specified deductions where income consists solely of securities receipts, disapplies certain loss set off provisions for securities gains, and anticipates rule based mechanisms for daily AUM attribution and digital filing requirements, aligning and refining the policy and operational features previously governed by Section 115AD and Rules 21AJ/21AJAA.
    Act RulesBills
    Show AI Summary
    Taxation of GDR income: concessional treatment for ESOP dividends and capital gains with notification based eligibility.
    Clause 193 of the Income Tax Bill, 2025 continues the concessional tax regime for dividends and long term capital gains on Global Depository Receipts acquired in foreign currency by resident employees under government notified ESOPs, limits deductions where gross total income consists solely of such GDR income, updates statutory cross references and definitions to current corporate law and IFSCs, and excludes certain computation benefits for GDR capital gains while preserving the notification requirement to restrict eligibility to approved schemes.
    Act RulesBills
    Show AI Summary
    Concessional tax regime for non resident bond and GDR income ensures specified rates, filing exemptions, and notification based eligibility.
    Clause 209 creates a concessional tax regime for non resident income from specified bonds and GDRs purchased in foreign currency, requiring purchase through an approved intermediary for GDRs under government notified schemes; it prescribes specific tax rates for interest, dividends and long term capital gains, restricts deductions where specified income is sole income, ring fences capital gains by disallowing set off provisions for computation, exempts non residents from return filing when TDS is applied, and preserves treatment on amalgamation or demerger.
    Act RulesBills
    Show AI Summary
    Taxation of offshore fund income: concessional rates for unit income and segregated treatment to prevent double deductions.
    Clause 208 establishes a special tax regime for overseas financial organisations investing in units purchased in foreign currency: concessional rates apply to income from such units and to long term capital gains, other income is taxed at normal rates with aggregation across heads, deductions are disallowed where gross total income consists solely of such concessional income while in mixed income cases concessional income must be segregated and deductions allowed only against the non concessional portion, and eligibility requires specified investment arrangements with prescribed Indian institutions plus SEBI approval with ''unit'' defined by cross reference to the schedule or UTI.
    Act RulesBills
    Show AI Summary
    Tax on provident fund accumulations: retrospective, year wise recalculation imposed when exemption conditions fail and tax withheld at payment.
    Clause 191 charges tax on an accumulated balance of a recognised provident fund when schedule exemption conditions are unmet, directing the Assessing Officer to perform a retrospective, year wise calculation of the notional tax that would have applied had the fund not been recognised and to charge the excess over tax actually paid in the year of payment, with trustees required to withhold tax at source on the taxable portion.
    Act RulesBills
    Show AI Summary
    Tax rates for non residents clarified: consolidated withholding regime, gross basis taxation, and filing exemptions streamlined.
    Clause 207 consolidates tax treatment of specified Indian source incomes of non residents and foreign companies by prescribing rates for dividends, interest, royalties and fees for technical services, preserving concessional rates for IFSC incomes and infrastructure debt funds, and treating residual income at normal rates. It mandates gross basis taxation by denying deductions under specified sections, excludes specified incomes from deduction computations under Chapter VIII (with an IFSC exception), streamlines approval requirements for royalties and FTS, and exempts non residents from return filing where such incomes alone are subject to prescribed withholding tax.
    Act RulesBills
    Show AI Summary
    Block assessment tax imposes a flat punitive rate on total income from search-derived block periods, broadening the tax base.
    Clause 192 taxes the total income of the block period as determined under section 294, replacing the narrower concept of "undisclosed income," and prescribes a flat 60% tax rate with applicable surcharge, thereby broadening the tax base for block assessments while aiming to simplify rate and surcharge determinations.
    Act RulesBills
    Show AI Summary
    Long-term capital gains taxation recalibrated to a higher concessional rate with STT linkage and IFSC carve-outs.
    Clause 198 establishes a revised LTCG regime for transfers of equity shares, equity oriented fund units, and business trust units where STT conditions are met, prescribing a codified concessional tax on specified LTCG with an IFSC exemption for foreign currency trades; it preserves marginal relief for resident individuals and HUFs, restricts the order of applying deductions and rebates against LTCG, defines equity oriented fund investment thresholds and averaging rules, and grants government power to notify exceptions to STT requirements.
    Act RulesBills
    Show AI Summary
    Long term capital gains taxation reformed: uniform lower rate, limited indexation grandfathering, and exemption limit relief retained.
    Clause 197 restructures long term capital gains taxation by imposing a uniform flat rate for most LTCG, removing indexation except for formulaic transitional relief for land and buildings acquired before the specified cut off, preserving basic exemption relief for resident individuals and HUFs by reducing LTCG by any shortfall in other income, excluding certain equity related instruments from its scope, and requiring deductions to be computed on gross total income excluding LTCG.
    Act RulesBills
    Show AI Summary
    Short-term capital gains tax regime tightened: higher flat rate for STT-eligible securities alters investor incentives and compliance obligations.
    Clause 196 targets short term capital gains from equity shares, equity oriented fund units and business trust units that are chargeable to STT, imposing a flat tax on such gains while preserving normal taxation of remaining income. It limits concessional treatment to exchange based STT transactions, provides relief by reducing eligible STCG where other income falls below the basic exemption, excludes IFSC foreign currency transactions, and allows Chapter VIII deductions only after reducing gross total income by the specified STCG.

    TMI Notes

    Back

    All TMI Notes

    Showing Results for :
    Reset Filters
      No Records Found

      TMI Notes

      Back

      All TMI Notes

      whatsappJoin Channel
      Showing Results for : Reset Filters

      Comparison of SCHEDULE VI "INCOME NOT TO BE INCLUDED IN TOTAL INCOME OF CERTAIN ELIGIBLE PERSONS IN INTERNATIONAL FINANCIAL SERVICES CENTRE OR HAVING INCOME THEREFROM" between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

      18 September, 2025

      Contents
      Acts
      Rules & Regulations
      Summary
      Note

      Note

      -

      Bookmark

      Print

      Print

      SCHEDULE VI - INCOME NOT TO BE INCLUDED IN TOTAL INCOME OF CERTAIN ELIGIBLE PERSONS IN INTERNATIONAL FINANCIAL SERVICES CENTRE OR HAVING INCOME THEREFROM

      Income-tax Act, 2025

      At a Glance

      Schedule VI in the Income Tax Bill, 2025 (Old Version). It lists categories of income not to be included in total income of certain eligible persons connected with International Financial Services Centres (IFSCs). It matters to non-residents, IFSC units, specified funds, offshore banking units, portfolio managers and investors in such funds. 

      Background & Scope

      Statutory hook: Schedule VI is presented "See section 11" and is annexed to the Income Tax Bill, 2025 (Old Version). The Schedule identifies income heads and categories of eligible persons whose specified incomes "shall not be included" in total income, subject to conditions in Column D and definitions in accompanying Notes. The Schedule addresses income relating to transfers on recognised stock exchanges in IFSCs, transfers of securities, income from securitisation trusts, derivative transactions with IFSC participants, royalty/interest on lease of aircraft/ship, portfolio management receipts, capital gains on shares of domestic companies with IFSC units, specified fund returns, dividend receipts from IFSC units engaged in leasing, and interest payable by IFSC units. Definitions and clarificatory notes appear as Note 1 through Note 7 and specify terms such as "convertible foreign exchange," "investment division of offshore banking unit," "manager," "permanent establishment," "securities," "securitisation trust," "specified fund," "sponsor," "trust," and "units." The Schedule incorporates cross-references to other statutes and regulations including the Reserve Bank of India, Securities and Exchange Board of India Regulations, the International Financial Services Centres Authority Acts/Regulations and the Special Economic Zones Act.

      Statutory Provision Mode

      Text & Scope

      Coverage: The Schedule is a table of 12 distinct items describing income types that are excluded from total income of defined eligible persons. Each row sets out (A) a description of income; (B) the eligible person; and (D) conditions for the exclusion. Core items include capital gains on transfers u/s 70(1)(r) on recognised IFSC exchanges (Sl.1), transfers of securities excluding shares of resident companies (Sl.2), income from non-resident issued securities (Sl.3), securitisation trust income (Sl.4), NDFs/ODIs/OTC derivatives transfers or distributions (Sl.5), royalty/interest on aircraft/ship leases (Sl.6), income from portfolios managed in IFSC contexts (Sl.7), capital gains on domestic company equity where the domestic company is an IFSC unit (Sl.8), income from specified funds (Sl.9), capital gains on transfer of shares of Indian resident companies linked to relocation to a resultant fund (Sl.10), dividends received by IFSC units engaged in leasing (Sl.11), and interest payable by IFSC units for borrowings on/after 1 September 2019 (Sl.12).

      Interpretation

      The Schedule operates as a negative inclusion clause-income of specified description shall not be included in total income when the conditions are satisfied. Legislative intent, as evidenced by cross-references and delegated prescription language, is to create tax neutrality or favourable tax treatment for financial activities routed through IFSCs and for specified funds and their non-resident unit-holders, subject to regulatory/formal conditions to prevent abuse. The repeated use of delegated-law phrasing ("as prescribed") indicates Parliament's intent to allow Central Government/Regulator-level granular conditions and computations to be specified by rules/regulations.

      Exceptions/Provisos

      Carve-outs: Many exclusions are conditional-e.g., Sl.1 requires consideration in convertible foreign exchange and that exemption be only to extent attributable to units held by non-residents or investment divisions of offshore banking units. Sl.3 requires that the income otherwise does not accrue or arise in India. Sl.6 requires that the paying IFSC unit has commenced operations on or before 31 March 2030. Sl.8 confines the capital gains exclusion to specified 10-year windows from commencement of operations (or from 1 April 2023 where applicable). Sl.10 requires transfer to a resultant fund via relocation and restricts the benefit to the extent attributable to units held by non-residents. Several notes set out detailed definitional provisos; for instance, "specified fund" requires Category III AIF registration or IFSC fund regulation and unit-holding restrictions (allowing a sponsor/manager unit and limited resident holdings up to 5% subject to conditions).

      Illustrations

      • Fund A, a trust in an IFSC with all units held by non-residents, sells securities on a recognised IFSC exchange and receives convertible foreign exchange. The capital gains on the transfer may be excluded from total income of the specified fund subject to the computation rules (Not stated in the document: precise computation formula).
      • Non-resident investor receives distribution from an offshore derivative instrument entered into with an offshore banking unit in an IFSC. If the contract is with an offshore banking unit or an FPI unit of IFSC and conditions as prescribed are met, the income may be excluded from the non-resident's total income.
      • A domestic company that is an IFSC unit engaged primarily in aircraft leasing commences operations on 1 April 2024. Capital gains arising on transfer of its equity in a tax year within ten tax years may be excluded for an eligible non-resident or IFSC unit purchaser, subject to the stated conditions.

      Interplay

      The Schedule expressly references several external statutes and regulatory instruments: the Foreign Exchange Management Act, 1999 (for convertible foreign exchange), SEBI AIF Regulations, 2012, SEBI FPI Regulations, 2019, IFSC Authority (Fund Management) Regulations, 2022, IFSC Authority (Capital Market Intermediaries) Regulations, 2021, Special Economic Zones Act (for definition of Unit), and domestic Income-tax Act sections (section 70(1)(r), section 70(2), section 173(c), section 221(6)(d)). The Schedule anticipates delegated rules for computation and qualification ("as prescribed"), indicating reliance on subsequent notifications/circulars to operationalise conditions and valuation/computation methodologies. Specific cross-references (e.g., to section 147 for IFSC units) are used to tie tax treatment to statutory characterisation of IFSC entities.

      Differences Between Documents

      • (Sl. No. 9) - Treatment of income from a specified fund or on transfer of units: Document 1 (Schedule VI of Income-tax Act, 2025) explicitly records the entry in Column D as "Nil." Document 2 (Income Tax Bill, 2025 - Old Version) leaves Column D blank (non-filled).
        • Practical impact: The Act version removes doubt by expressly providing nil conditions for the eligible person, which clarifies that no further conditions are required for that entry; the Bill's version could have generated uncertainty on whether any qualifying conditions applied.
      • Drafting and formulation differences - use of legislative phrasing: Document 1 consistently uses "as may be prescribed" in several conditions (e.g., Sl. No.1(c) "shall be computed in such manner as may be prescribed"), whereas Document 2 often uses the shorter "as prescribed" or "as notified" in similar places.
        • Practical impact: The Act version's "as may be prescribed" is the conventional indicative of delegated legislation; the Bill's shorter phrasing is substantively similar but the Act wording aligns with settled legislative drafting norms and can be interpreted as a clearer delegation to rulemaking authorities.
      • Definitions structure for "specified fund" (Note 1(g)): There are re-arrangements and slight reformulations. Document 2 presents sub-clauses (A) and (B) and then (C) and (D) (with (C) stating location and (D) the unit-holding exceptions). Document 1 embeds the location requirement as part of the initial description ("a fund ... located in International Financial Services Centres") and then sets out regulatory regimes (I) and (II) and other descriptive elements.
        • Practical impact: The Act text (Document 1) is more tightly structured to associate regulatory regime and location in a single sentence which aids interpretation that location in an IFSC is an essential attribute; the Bill's layout might have been read as fragmented and therefore more ambiguous regarding whether regulation or location were independent requirements.
      • Specific phrase differences in examples and notes: e.g., Document 2 uses "monies" in Note to Sl. No. 12 whereas Document 1 uses "moneys" (spelling variation); Document 1 cites the International Financial Services Centres Authority regulations (with years) similarly to Document 2 but sometimes presents the regulatory citation with slightly different punctuation and parenthetical years.
        • Practical impact: These are drafting-level differences with minimal substantive effect but the Act's editorial consistency reduces risk of citation ambiguity.
      • Scope of some clauses (Sl. No. 5 and related notes): Document 1 expressly includes "over-the-counter derivatives" in the heading of clause 5(b) and in certain cross references, and clarifies that qualifying counterparty may be "an offshore banking unit of an International Financial Services Centre as referred to in section 147 or any Foreign Portfolio Investor being a unit of an International Financial Services Centre." Document 2 contains a similar formulation but with slightly different punctuation and omission of the phrase "as referred to in section 147" in one place.
        • Practical impact: Document 1's explicit cross-reference to section 147 and consistent phraseology provides stronger statutory linkage to IFSC units, reducing interpretive friction when applying provisions to offshore banking units and FPIs.
      • Computational/technical wording: Document 1 uses "shall have the meanings respectively assigned to them in the Notes below the said Table" and similar phrasing; Document 2 has near identical phrasing but differs in capitalization and small syntactic points.
        • Practical impact: No substantive difference; primarily editorial and drafting refinement in the Act.

      Practical Implications

      • Compliance and risk areas: Taxpayers and fund managers must ensure strict compliance with the unit-holding criteria for "specified funds" (non-resident majority with narrow resident exceptions) and with commencement-of-operations timelines (notably 31 March 2030). Failure to meet conditions will negate the exclusion. Reliance on delegated rules is necessary for computation-non-availability of notified rules would create compliance risk.
      • Record-keeping/evidence: The text implies the need to maintain documentary evidence of (i) convertible foreign exchange receipt, (ii) unit-holding registers showing resident/non-resident status and percentages, (iii) documentation of transfers on recognised IFSC stock exchanges, (iv) contracts with offshore banking units/FPIs for derivative transactions, (v) dates of commencement of operations for IFSC units, and (vi) particulars of relocation transfers between original and resultant funds. The Schedule itself does not prescribe specific documents-administrative rules likely will.

      Key Takeaways

      • Schedule VI lists discrete income categories excluded from total income for specified IFSC-related actors, subject to conditions and definitions.
      • The exclusions primarily benefit non-residents, IFSC units, specified funds and their non-resident unit-holders to foster IFSC financial activity.
      • Many exclusions are conditional (convertible foreign exchange, unit-holding restrictions, commencement dates, 10-year windows), making eligibility fact-sensitive.
      • The Schedule relies on external regulations and delegated "prescribed" rules for computation and detailed conditions; absence of those rules may impede operational application.
      • Robust records proving non-resident status of unit-holders, transactional currency, dates of commencement and contractual counterparties will be central to claiming the exclusions.
      • Some drafting ambiguities in the Bill may have been clarified in subsequent Act drafting (e.g., explicit "Nil." for Sl.9 in the Act), underscoring the importance of checking final enacted text and notifications.

      Full Text:

      SCHEDULE VI - INCOME NOT TO BE INCLUDED IN TOTAL INCOME OF CERTAIN ELIGIBLE PERSONS IN INTERNATIONAL FINANCIAL SERVICES CENTRE OR HAVING INCOME THEREFROM

      Topics

      ActsIncome Tax