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Case lawCBDT Circulars & Instructions › Statutory position — s.10(23FBA) and s.10(23FBB): the two clauses that put an AIF's business income at fund level and everything else at investor level
CBDT Circulars & InstructionsCuts both waysValidity unconfirmeds.10(23FBA)s.10(23FBB)s.10(23FB)s.115UBs.115Us.194LBBs.139(4F)Rule 12CB

Statutory position — s.10(23FBA) and s.10(23FBB): the two clauses that put an AIF's business income at fund level and everything else at investor level

The Assessing Officer has re-labelled my Category II AIF's interest and gains as business income. Which provision actually decides whether income is taxed in the fund's hands or in the investor's, because section 115UB does not say so in terms?

The Assessing Officer has re-labelled my Category II AIF's interest and gains as business income. Which provision actually decides whether income is taxed in the fund's hands or in the investor's, because section 115UB does not say so in terms?

It is not section 115UB that draws the line; it is clauses (23FBA) and (23FBB) of section 10, both inserted by section 7(III)(c) of the Finance Act, 2015 with effect from 1 April 2016. Clause (23FBA) exempts any income of an investment fund OTHER than income chargeable under the head "Profits and gains of business or profession", so the fund itself is charged only on its business income. Clause (23FBB) exempts, in the unit holder's hands, that proportion of the income referred to in section 115UB which is of the same nature as income chargeable under that head, so the investor is not charged on the slice the fund has already been taxed on. The line is drawn by HEAD of income, and by nothing else. The Explanation to the two clauses ties "investment fund" to clause (a) of Explanation 1 to section 115UB, which is why a Category III Alternative Investment Fund gets neither clause.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2016-04-01, reported as Clauses (23FBA) and (23FBB) and the proviso to clause (23FB) as inserted by section 7(III)(b) and (c) of the Finance Act, 2015 (indiankanoon.org/doc/127799810/); Explanation 1 to section 115UB on incometaxindia.gov.in/w/section-115ub (Year 2026). It bears on section 10(23FBA), section 10(23FBB), section 10(23FB), section 115UB, section 115U, section 194LBB, section 139(4F), section Rule 12CB of the Income Tax Act 1961, in Charitable Trusts & Exemption, Capital Gains Exemptions and How Tax Law Is Read matters.

Validity check could not be completed. Validity check could not be completed. The two clauses are quoted from the enacting words of the Finance Act, 2015 because no consolidated departmental page for section 10 could be read as far as them. The definition they depend on was read on the departmental Year 2026 page for section 115UB and is current. Whether the clauses themselves have been amended since 2015 was not established, and no judicial treatment was searched for.

Why it matters

Section 115UB itself contains no carve-out of business income from the pass-through — the whole of the fund-level charge on business income and the whole of the investor-level exemption for it live in these two clauses of section 10, which are easy to miss because they sit hundreds of clauses away from the section they operate on. Three consequences follow. First, because the test is the HEAD under which income is chargeable and not a description of the activity, an Assessing Officer who re-characterises a fund's interest, capital gains or fee receipts as business income does not merely move the income; he destroys the pass-through for that whole stream, taxing it in the fund's hands and taking it out of the investor's return. That is the fight worth having at the assessment stage rather than later. Second, the two clauses are complementary and have to be applied together: if a stream is business income in the fund's hands under clause (23FBA), the investor's share of it must be exempt under clause (23FBB), and a computation that taxes the same stream in both places is wrong on the face of it. Third, the same Finance Act closed the older venture capital route for these funds. Section 7(III)(b) inserted a proviso to clause (23FB) providing that nothing contained in that clause shall apply in respect of any income of a venture capital company or venture capital fund, being an investment fund specified in clause (a) of Explanation 1 to section 115UB, of the previous year relevant to the assessment year beginning on or after 1 April 2016. A fund that is within section 115UB therefore cannot fall back on clause (23FB); the two regimes are mutually exclusive from that year.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

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