VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — rule 10V: the look-through for institutional investors, the cure periods that save a breach, and the twenty-six per cent control test
CBDT Circulars & InstructionsCuts both waysRule 10Vs.9As.9A(3)s.9A(5)s.90s.90A

Statutory position — rule 10V: the look-through for institutional investors, the cure periods that save a breach, and the twenty-six per cent control test

My offshore fund breached one of the section 9A(3) conditions for part of the year, and one of its investors is itself a pooling vehicle. Is the safe harbour lost for the whole year?

My offshore fund breached one of the section 9A(3) conditions for part of the year, and one of its investors is itself a pooling vehicle. Is the safe harbour lost for the whole year?

Not necessarily. Rule 10V(3) provides that a fund shall not be denied the benefit of being an eligible fund where non-fulfilment of conditions (c), (d) or (e) of section 9A(3) is for reasons beyond the fund's control and does not exceed ninety days, or does not exceed eighteen months from the date the fund is set up or the final closing of the fund, whichever is earlier, where bona fide efforts are made, or arises because the fund is being wound up and does not exceed one year from the date the winding-up process began; and it gives the same protection where the delay in furnishing the section 9A(5) statement does not exceed ninety days. Rule 10V(1) separately requires a look-through where the investment has been made directly by an institutional entity, and rule 10V(4) fixes the point at which the fund is said to control or manage a business in India for condition (k) at a holding exceeding twenty-six per cent.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2025-04-01, reported as Income-tax Rules 1962, rule 10V, sub-rules (1), (2), (3) and (4), as printed on the Income-tax Department's rule page; the page carries no year stamp, the rule could not be dated, and the date in 'decided_on' is a PLACEHOLDER only — it is not a commencement date for this rule and nothing should be inferred from it.. It bears on section Rule 10V, section 9A, section 9A(3), section 9A(5), section 90, section 90A of the Income Tax Act 1961, in Residence & Treaty Benefit and How Tax Law Is Read matters.

Still good law. The date in 'decided_on' is a placeholder, not a commencement: it is borrowed from the version of section 9A read alongside this rule and carries no legislative meaning for rule 10V. Note that the same date appears as a genuine commencement date in other entries of this batch, so it must be read with this note. Validity could not be fully checked. The rule text is as printed on the Income-tax Department's own rule page, which carries no year stamp, so I cannot say from that page whether the rule has been amended more recently, and I did not locate a notification amending it. The conditions the rule refers to — clauses (c), (d), (e) and (k) of section 9A(3) — were read this pass on the Department's section page carrying the year stamp 2025 and correspond to the conditions the rule names. No judicial decision construing rule 10V was located: an indiankanoon search on 8 September 2026 for 'section 9A' with 'eligible fund manager' returned the rule's own bare text and SEBI regulations pages and no judgment or Tribunal order. Sub-rules (1), (2), (3) and (4) were re-read word-for-word on the indiankanoon bare-rule text of rule 10V (doc 60297115) and came back identical — a route independent of the Department. That text is an earlier consolidation running only to sub-rule (12), which shows that the present sub-rules (13), (14) and (15) are later and that sub-rules (5) to (10), which the present sub-rule (11) disapplies on and after 1 April 2019, were once the operative reporting machinery.

Why it matters

Practitioners reading section 9A alone conclude that a temporary breach is fatal, because the section itself contains no tolerance. All of the tolerance sits in the rule, and it is confined: it covers only conditions (c) — the five per cent resident participation ceiling — (d) — the investor protection regulation condition — and (e) — the twenty-five member floor. It does not extend to the corpus floor in condition (j), to the concentration conditions in (f), (g), (h) and (i), or to the remuneration condition in (m). The look-through in rule 10V(1) cuts both ways: where a pooling entity invests directly, the number of members and the participation interest are determined by looking through it, but only if that entity independently satisfies conditions (c), (e), (f) and (g) of section 9A(3), was set up solely for pooling funds and investment, and is resident of a treaty or notified country. Rule 10V(2) then imposes a due diligence obligation on the fund itself where the direct investor is not a natural person, with a proviso that lets the fund rely on a written declaration where the direct investor is a Government, a Central bank, a sovereign fund, a multilateral agency, or an appropriately regulated pension fund, University fund, bank or collective investment vehicle such as a mutual fund. The twenty-six per cent figure in rule 10V(4) is the single most useful number in the machinery: it converts the open-ended words 'control and manage' in condition (k) into an arithmetic test.

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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Related

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