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Borrowing
Act Rules Indian Laws
Regulation 107 of the International Financial Services Centres Authority (Fund Management) Regulatio...
Borrowing and leveraging by a Family Investment Fund are permitted in accordance with its risk management policy under the International Financial Services Centres Authority (Fund Management) Regulations, 2025.

Permissible investments
Act Rules Indian Laws
Regulation 106 of the International Financial Services Centres Authority (Fund Management) Regulatio...
Permissible investments by a Family Investment Fund, subject to applicable regulatory conditions and Authority-specified limits, include securities, money market and debt instruments, securitised debt, investment-scheme units, derivatives, limited liability partnerships and physical assets. Investments may be made in IFSC, India or foreign jurisdictions. Additional securities, financial products, assets or instruments may be permitted where specified by the Authority.

Permissible Activities
Act Rules Indian Laws
Regulation 105 of the International Financial Services Centres Authority (Fund Management) Regulatio...
Family Investment Fund permissible activities include all activities connected with managing the fund. Additional activities may be undertaken where specified by the Authority, allowing the operational scope to extend beyond core fund-management functions in accordance with those specifications.

Eligibility Conditions
Act Rules Indian Laws
Regulation 104 of the International Financial Services Centres Authority (Fund Management) Regulatio...
Family Investment Funds may be constituted as companies, contributory trusts, limited liability partnerships, or other permitted forms. Contributory trusts must ensure identifiable beneficiaries, determinable beneficiary shares, and that subsequent contributions do not make beneficiaries or their interests indeterminate. The fund must maintain a minimum investment of USD 10 million within three years of registration. Additional investment vehicles may be established upon filing documents and paying applicable fees, and are aggregated with the fund for the minimum-investment condition.

Regulation 103 of the International Financial Services Centres Authority (Fund Management) Regulatio...
Unlisted Investment Trusts may voluntarily surrender their certificate of registration to the Authority. On acceptance, they must cease carrying on Investment Trust activities. The Investment Trust and its parties remain liable for all past acts, omissions and commissions connected with those activities despite surrender of registration.

Valuation of assets
Act Rules Indian Laws
Regulation 102 of the International Financial Services Centres Authority (Fund Management) Regulatio...
Investment Trusts must obtain annual and half-yearly asset valuations, with quarterly valuations for InvITs exceeding the prescribed borrowing and deferred-payment threshold. Listed InvITs must submit valuation reports to recognised stock exchanges. Public unit issues generally require a current full valuation included in the offer document. Asset purchases or sales departing beyond prescribed margins from assessed value require unit holder approval. Material developments affecting value require prompt revaluation and disclosure. Valuers are restricted from valuing assets connected with their recent acquisition or disposal involvement.

Regulation 101 of the International Financial Services Centres Authority (Fund Management) Regulatio...
Listed Investment Trusts may issue listed debt securities and must comply with consolidated borrowing and deferred-payment limits, net of cash and cash equivalents. Further borrowings exceeding 25% of asset value require a credit rating and unitholder approval. InvIT borrowings above 49% additionally require an AAA or equivalent rating, use solely for infrastructure acquisition or development, a record of six continuous post-listing distributions, and prior unitholder approval. Market-driven breaches must be rectified within six months.

Distribution policy
Act Rules Indian Laws
Regulation 100 of the International Financial Services Centres Authority (Fund Management) Regulatio...
Regulation 100 requires Investment Trusts, holdcos and SPVs to distribute prescribed portions of net distributable cash flows through the investment structure to unitholders. Publicly offered InvITs must make distributions at least once every six months and within 15 days of declaration. Sale proceeds from infrastructure assets, properties, or interests in holdcos or SPVs need not be distributed if proposed for reinvestment; where reinvestment is not proposed within one year, the proceeds must be distributed under the applicable cash-flow distribution requirements.

Regulation 99 of the International Financial Services Centres Authority (Fund Management) Regulation...
Regulation 99 requires public-offer REITs to maintain at least 75% of assets in income-producing real estate, restricts development and uncompleted-property exposure, limits specified single-issuer or manager exposure, and caps non-permissible revenue. Certain breaches caused by market, tenancy, lease-expiry, or property-sale events must be notified to the trustee and rectified within the prescribed period, subject to possible unitholder-approved extension. Private-placement REITs must maintain at least 80% of asset value in eligible real estate and may invest unutilised funds only in specified permitted instruments.

Circular No. Order No. F.3(377)/GST/POLICY/2021/2155-64 Dated:- 26-11-2024 Delhi SGST Dated:- 26-11-...
Powers under the first proviso to sub-rule (1) of Rule 23 of the Delhi Goods and Services Tax Rules, 2017 are delegated to every concerned Zonal Incharge. The delegation operates for all eligible cases governed by the amended provisions of Section 30(1) of the Delhi Goods and Services Tax Act, 2017, with effect from 1 October 2023.

Regulation 98 of the International Financial Services Centres Authority (Fund Management) Regulation...
Public-issue InvITs must invest at least 80% of asset value in completed and revenue-generating infrastructure projects, with only direct qualifying project investments through holdcos or SPVs counted toward that threshold. Up to 20% may be invested in specified ancillary assets, while under-construction infrastructure projects are separately capped at 10%. Market-driven breaches require trustee notification and restoration of compliance within the prescribed period. Privately placed InvITs must invest at least 80% in eligible infrastructure projects and may place uninvested funds in specified permitted securities and cash-equivalent instruments.

2020 (10) TMI 1408
Case Laws Income Tax
Transfer-pricing comparability adjustments require material functional and cost differences to be examined, with matching-period data where quarterly results exist.
Transfer-pricing comparability requires adjustments for material differences in import content, raw-material consumption, capacity utilisation and scrap sales; separate working-capital adjustment may be unnecessary where those differences are addressed. Safe Harbour Rules introduced prospectively cannot govern prior transfer-pricing documentation, and provision write-backs may be operating items. Companies with product, brand, significant research-and-development or functionally diverse operations may be unsuitable comparables, while different financial years may be reconciled through audited quarterly data. Warranty provisions require a present sales-related obligation, probable outflow and reliable estimation. Actual bad-debt write-offs and business-linked trade-advance write-offs may qualify for deduction, and depreciation must follow binding directions.

Investment Conditions
Act Rules Indian Laws
Regulation 97 of the International Financial Services Centres Authority (Fund Management) Regulation...
Investment Trusts may invest through SPVs or holdcos subject to non-interference with regulatory compliance, contractual dispute-resolution mechanisms, board-governance requirements, and exercise of voting rights. Holdco structures require an ultimate holding interest of at least 26 per cent in underlying SPVs. Foreign investments must comply with applicable local laws. Completed rent-generating property and infrastructure assets are generally subject to a minimum holding period, and significant sales require prior unitholder approval. Investment in other Investment Trust units is prohibited, while lending is limited to investee holdcos or SPVs.

Regulation 96 of the International Financial Services Centres Authority (Fund Management) Regulation...
Listed Investment Trusts must meet the continuous obligations and disclosure requirements of the recognised stock exchange. For unlisted Investment Trusts, the investment manager must provide annual, half-yearly and valuation reports to the trustee and unit holders. It must disclose material operational or performance-related information, including significant asset transactions, additional unit issues, credit-rating changes, unit-holder approval matters, significant legal proceedings, meeting notices and results, regulatory non-compliance, limit breaches, and other material matters requiring disclosure.

Regulation 95 of the International Financial Services Centres Authority (Fund Management) Regulation...
Offer documents and placement memoranda for Investment Trusts must provide material, true, correct and adequate disclosures for informed investment decisions. Required disclosures include details of relevant parties, assets, strategy, leverage, conflicts, valuation, financials, unit-holder rights, title matters, litigation, regulatory actions, risks and taxation. Specified valuation, project-management, due-diligence and stock exchange approval materials must be submitted to the Authority. Unlisted Investment Trusts must make applicable disclosures required for listed Investment Trusts.

Public Issues
Act Rules Indian Laws
Regulation 94 of the International Financial Services Centres Authority (Fund Management) Regulation...
Public fund raising by an Investment Trust requires advance filing and public availability of a draft offer document, supported by due diligence certification and incorporation of Authority comments before filing the offer document. Offers must comply with prescribed timing, subscription, allotment, dematerialisation and pricing requirements. Refund obligations apply where minimum subscription thresholds are not met or subscriptions exceed permitted limits. Retained oversubscription is capped, requires disclosure, and cannot fund general purposes. Offers for sale are subject to a minimum holding period, while general-purpose use of issue proceeds is restricted.

Regulation 93 of the International Financial Services Centres Authority (Fund Management) Regulation...
Private placement without listing by an Investment Trust requires advance filing of a draft placement memorandum with the Authority and payment of the applicable fee at least five working days before the issue opens. The issue must open within three months after the placement memorandum is taken on record. Fund raising is limited to investors committing at least USD 250,000 or accredited investors, with a maximum of fifty investors. A final placement memorandum must be filed within ten working days after unit allotment.

Private Placement With Listing
Act Rules Indian Laws
Regulation 92 of the International Financial Services Centres Authority (Fund Management) Regulation...
Private placement with listing by an Investment Trust requires in-principle approval from recognised stock exchange(s) and filing of a placement memorandum with the Authority at least five working days before opening the issue. Funds may be raised from accredited investors or investors committing at least USD 150,000, subject to a USD 1 million minimum where less than eighty per cent of asset value is invested in completed and revenue-generating assets. The offering must have between two and one thousand investors, and the final placement memorandum must be filed within ten working days after listing.

Regulation 91 of the International Financial Services Centres Authority (Fund Management) Regulation...
Initial offers of Investment Trust units require registration, minimum asset value, and a minimum offer size. Where units are proposed to be listed on a recognised stock exchange, the minimum public offer and allotment is determined by post-issue capital through percentage-based or value-based thresholds. Units offered to the sponsor, investment manager, project manager, or their related parties or associates cannot be counted as units offered to the public.

Currency
Act Rules Indian Laws
Regulation 90 of the International Financial Services Centres Authority (Fund Management) Regulation...
Investment Trust units may be issued only in a freely convertible foreign currency. The currency-denomination requirement applies under Regulation 90 of the International Financial Services Centres Authority (Fund Management) Regulations, 2025.

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