Circular No. 9/2022 — Guidelines for 10(23FE) — sovereign wealth funds

Date: 2022-05-09 Status: ACTIVE Category: Exemptions Binding on Department: Yes (Section 119 / Section 400 IT Act 2025)

Summary

Guidelines for exemption of sovereign wealth funds and pension funds under section 10(23FE).

Key Directions

  1. Exemption for specified income from investments in India.
  2. Minimum investment commitment Rs.3,000 crore.
  3. Investment held for minimum 3 years.
  4. Detailed annual reporting required.

Applicability Under IT Act 2025

Saving Clause: Section 536 of IT Act 2025 saves circulars issued under the 1961 Act “so far as not inconsistent” with the new Act.

Old Section (1961 Act)New Section (2025 Act)Consistent?
10(23FE)19Yes

Cross-References

Act Sections

  • Section 10(23FE)
  • Section 19
  • None identified

Key Case Law (Circular Supremacy)

  • To be populated — cases where this circular was cited/applied

Full Text

Full text to be added — see raw/circulars/ for PDF when available

Source