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Case lawCBDT Circulars & Instructions › Statutory position — s.10(23FC): the business trust's own exemption for interest and for dividend from a special purpose vehicle, and what a "special purpose vehicle" is
CBDT Circulars & InstructionsCuts both waysValidity unconfirmeds.10(23FC)s.10(23FCA)s.10(23FD)s.115UAs.115UA(2)s.115UA(3)s.194LBAs.194LBA(2A)s.115BAAs.2(13A)s.56(2)(xii)

Statutory position — s.10(23FC): the business trust's own exemption for interest and for dividend from a special purpose vehicle, and what a "special purpose vehicle" is

My client is a registered InvIT. It receives interest and dividend from the project companies it controls. Is that income taxed in the trust's hands, and if not, where does the charge go?

My client is a registered InvIT. It receives interest and dividend from the project companies it controls. Is that income taxed in the trust's hands, and if not, where does the charge go?

Neither is taxed in the trust's hands. Clause (23FC) of section 10 keeps out of the trust's total income (a) interest received or receivable from a special purpose vehicle and (b) dividend received or receivable from a special purpose vehicle. The charge does not disappear: section 115UA(3) moves income of the nature described in clause (23FC) to the unit holder, and section 10(23FD) — which exempts the rest of a distribution in the unit holder's hands — expressly does not cover the interest limb, and does not cover the dividend limb where the special purpose vehicle has exercised the option under section 115BAA. A "special purpose vehicle" is defined inside the clause itself as an Indian company in which the business trust holds controlling interest and any specific percentage of shareholding or interest required by the regulations under which the trust is registered.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2021-04-01, reported as Clause (23FC) as inserted by s.5(b) of the Finance (No. 2) Act, 2014 (indiankanoon.org/doc/151046659/); sub-clause (b) as substituted by s.7(II)(b) of the Finance Act, 2020 (indiankanoon.org/doc/64850385/); the sub-clause (a)/(b) structure and the s.115BAA switch confirmed on incometaxindia.gov.in/w/section-194lba-10 (Year 2024 No. 2) and /w/section-194lba-5 (Year 2019 No. 2). It bears on section 10(23FC), section 10(23FCA), section 10(23FD), section 115UA, section 115UA(2), section 115UA(3), section 194LBA, section 194LBA(2A), section 115BAA, section 2(13A), section 56(2)(xii) of the Income Tax Act 1961, in Charitable Trusts & Exemption, Capital Gains Exemptions and TDS Defaults matters.

Validity check could not be completed. Validity check could not be completed. The clause as it now stands could not be read on any consolidated departmental page, because nine departmental section 10 URLs were fetched and none reached clause (23FC), the furthest any of them reaching clause (23DA); what is stated here is built from the enacting words of the Finance (No. 2) Act, 2014, the amending words of the Finance Act, 2020 and the cross-references in two year-stamped departmental section 194LBA pages, one of 2019 vintage and one of 2024. Whether any Finance Act after 2020 has further amended clause (23FC) was not established, and no judicial treatment was searched for.

Why it matters

This is the hinge of the whole business trust regime, and it is where readers most often go wrong by treating the trust as tax-free. It is not tax-free: section 115UA(2) charges the trust's total income at the maximum marginal rate, and clause (23FC) is one of the two carve-outs that keep specified streams out of that total income so that they can be taxed one level up instead. Four points decide live disputes. First, the exemption is confined to income from a special purpose vehicle as defined in the clause — an Indian company that the trust controls in the manner the SEBI regulations require. Interest from a bank deposit, from a loan to an outsider, or from a company that is not an SPV in that sense is not within clause (23FC) at all and stays in the trust's own total income under section 115UA(2). Second, the two limbs behave differently downstream: the interest limb is always taxable in the unit holder's hands, while the dividend limb is taxable in his hands only if the SPV has opted into the concessional corporate rate in section 115BAA, and is otherwise exempt to him under section 10(23FD). Third, the withholding machinery mirrors that split exactly — section 194LBA(2) deducts five per cent on the sub-clause (a) stream and ten per cent on the sub-clause (b) stream for a non-resident unit holder, and section 194LBA(2A) switches deduction off altogether for the sub-clause (b) stream where the SPV has not exercised the section 115BAA option. That is the cleanest independent confirmation available that the clause has two sub-clauses and which is which. Fourth, nothing in clause (23FC) touches a distribution that is repayment of shareholder debt; that stream falls outside clause (23FC) and outside clause (23FCA), and since 1 April 2024 it is caught in the unit holder's hands by section 56(2)(xii).

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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