Circular No. 11/2025 — Modification to circular no. 9 of 2022 f. no.370142/2/2022 tpl dated 09.05.2022 of CBDT

What this is

Circular No. 11/2025 was issued by the Central Board of Direct Taxes on 2 September 2025. Its subject is Modification to circular no. 9 of 2022 f. no.370142/2/2022 tpl dated 09.05.2022 of CBDT.

These are guidelines issued under a power in the section itself. Where a section says the Board may issue guidelines and that they bind, the guidelines carry more weight than an ordinary circular — read the enabling words before deciding which kind this is.

What it does

Amends the Board's own guidelines on the sovereign wealth fund and pension fund exemption in clause (23FE) of section 10, which were issued as Circular No. 9 of 2022. The Finance Act, 2025 pushed the outer date for making a qualifying investment under that clause from 31 March 2025 to 31 March 2030, with effect from 1 April 2025. To match, the dates appearing in the opening paragraph and in paragraphs 4.6.2 and 4.6.3 of the 2022 circular are now to be read as 31 March 2030, with effect from 1 April 2025. Nothing else in the 2022 guidelines is touched.

Why it was issued

The investment window in clause (23FE) of section 10 was extended by the Finance Act, 2025, and the Board's guidelines still carried the older date.

Who it reaches

Notified sovereign wealth funds claiming exemption under clause (23FE) of section 10
Notified pension funds investing in Indian infrastructure under that clause
Investee companies and infrastructure entities relying on the 2022 guidelines
Advisers applying paragraphs 4.6.2 and 4.6.3 of Circular No. 9 of 2022

The provisions it speaks to

Left, the provision of the Income-tax Act, 1961 as the instrument itself names it. Right, the section of the Income-tax Act, 2025 that the department’s own concordance maps it to — which is where the same ground is now covered.

Under the 1961 Act	Now
s.10	s.11, s.19

The instrument, as the Board published it

The department publishes this one only as a PDF, so the words below were read out of that PDF by machine. That reading can carry its own mistakes — a misread number, a broken line. Check the signed document before you rely on a figure in it.

F.No.370142/32/2025-TPL
Government of India
Ministry of Finance
Department of Revenue
Circular No. II of 2025
Central Board of Direct Taxes (TPL Division)
Nf
Dated: 02, September, 2025
Sub:- Modification to Circular No. 9 of 2022 (F. No.370142/2/2022-TPL) dated
09.05.2022 of CBDT-reg.
Reference is invited to Circular No. 9 of 2022 (F.No.370142/2/2022-TPL) dated
09.05.2022 of Central Board of Direct Taxes (the 'Board') vide which guidelines under clause
(23FE) of section 10 of the Income-tax Act, 1961 (the Act) were prescribed.
2. Clause (23FE) of section 10 of the Act was amended, vide Finance Act, 2025, so as to
extend the date of inves~mcnt under the said clause from 31st day of March, 2025 to 31st day
of March, 2030. The said amendment is effective from the pt day of April, 2025.
3. In view of the above, reference to the date 31.03.2024 in the opening para and to the
date 31 st March, 2024 in paras 4.6.2 and 4.6.3 of the said circular, shall be read as 31 st March,
2030 with effect from the 1st day of April, 2025.
Copy to the:
1. PS/OSD to FM/ PS/OSD to MoS(F).
2. PS to the Finance Secretary.
3. PS to the Revenue Secretary.
4. Chairman and Members, CBDT.
/
(Rohit Singh)
Under Secretary (TPL-I)
CBDT, New Delhi
5. Joint Secretaries/ CsIT/Directors/Deputy Secretaries/Under Secretaries, CBDT.
6. C&AG oflndia (30 copies).
7. JS & Legal Advisor, Ministry of Law & Justice, New Delhi.
8. Institute of Chartered Accountants oflndia.
9. CIT (M&TP), Official Spokesperson of CBDT.
10. Principal DGIT (Systems) for uploading on the departmental Website.
~ '7l__/
(Rohit Singh)
Under Secretary (TPL-I)
CBDT, New Delhi

What to watch

This is a date substitution in an existing circular, not a fresh set of guidelines; you still have to read Circular No. 9 of 2022 for the substance.
The substitution runs only from 1 April 2025, so a period before that is read on the old text.
The copy in front of me is a scan with clear OCR damage - the circular number itself is rendered as 'II of 2025' - so verify the number against the gazetted text.
The scanned text describes the statutory change as running from 31 March 2025 to 31 March 2030 but directs a date of 31 March 2024 in the 2022 circular to be read as 31 March 2030; that mismatch may be a scanning error, so check the published circular before relying on which date is being replaced.

Where you meet it

When an exemption claim under clause (23FE) of section 10 turns on whether the investment was made within the permitted window, whether in assessment or in a withholding certificate application.

What it names

It mentions. Circular No. 9/2022

On the same provision

Other instruments in this library that name the same provision of the 1961 Act. They are not necessarily still operative, and a later one may have replaced an earlier one without saying so.

Notification No. 116/2026 [F. No.195/13/2025-ITA-I] / SO 4706(E) : Notification in the case of Maharashtra Electricity Regulatory Commission — [भाग II—खण् ड 3(ii)] भारत का रािपत्र : असाधारण 3 25 August 2026
Notification No. 112/2026 [F. No. 300196/6/2026-ITA-I] / SO 4458(E) : Notification in the case of District Legal Service Authority, Panchkula — Ministry of Finance 11 August 2026
Notification No. 109/2026 [F. No. 300196/39/2025-ITA-I] / SO 4321(E) : Notification section 536 (1) of the Income Tax Act, 2025 (30 of 2025) in the case of Odisha Joint Entrance Examination Committee — [भाग II—खण् ड 3(ii)] भारत का रािपत्र : असाधारण 3 4 August 2026
Notification No. 107/2026 [F. No. 300196/65/2018-ITA-I] / SO 4319(E) : Notification section 536 (1) of the Income Tax Act, 2025 (30 of 2025) in the case of Noida Special Economic Zone Authority — [भाग II—खण् ड 3(ii)] भारत का रािपत्र : असाधारण 3 4 August 2026
Notification No. 106/2026 [F. No. 300196/65/2018-ITA-I] / SO 4318(E) : Notification section 536 (1) of the Income Tax Act, 2025 (30 of 2025) in the case of Noida Special Economic Zone Authority — [भाग II—खण् ड 3(ii)] भारत का रािपत्र : असाधारण 3 4 August 2026
Notification No. 104/2026 [F.No.300196/1/2026-ITA-I] / SO 4308(E) : Notification section 536 (1) of the Income Tax Act, 2025 (30 of 2025) in the case of District Legal Service Authority, Charkhi Dadri — Ministry of Finance 3 August 2026

← Circular No. 12/2025 · Circular No. 10/2025 →

A circular binds the department, not you and not a court. The Board issues a circular to its own officers. An assessee may hold the department to a circular that helps him; the department cannot hold an assessee to one that hurts him, and the Tribunal and the courts decide the law for themselves.

Source: the Income Tax Department’s own published text — its page for this instrument.