Notification No. 92/2025 [F. No. 500/Misc./S10(23FE)/FT&TR-II] / S.O. 3146(E)

What it does

The Central Government amends its notification S.O. 1889(E) dated 17 May 2021 (Notification No. 67/2021), issued under sub-clause (iv) of clause (c) of Explanation 1 to clause (23FE) of section 10 of the Income-tax Act, 1961, by which a fund was notified for the section 10(23FE) exemption. In the opening paragraph of that notification, the words "31st day of March, 2025" are substituted by "31st day of March, 2030". The outer date for qualifying investments under the parent notification therefore moves forward by five years.

Who it reaches

The fund notified by S.O. 1889(E) dated 17 May 2021
Indian investee companies, infrastructure entities and funds receiving its investment
Assessing Officers testing the investment date condition under section 10(23FE)

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.3	s.3
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.

MINISTRY OF FINANCE
(Department of Revenue)
(CENTRAL BOARD OF DIRECT TAXES)
NOTIFICATION
New Delhi, the 11th July, 2025
S.O. 3146(E).— In exercise of the powers conferred by sub-clause (iv) of clause (c) of Explanation 1 to clause (23FE) of section 10 of the Income-tax Act, 1961 (43 of 1961), the Central Government hereby makes the following further amendment in the notification of the Government of India in the Ministry of Finance, Department of Revenue (Central Board of Direct Taxes) (Notification No. 67 /2021/ F. No. 370142/18/2021-TPL) number S.O. 1889(E), dated the 17th May, 2021 published in the Gazette of India, Extraordinary, Part II, section 3, sub-section (ii), except as respects things done or omitted to be done on and from the 1st April, 2025 till the date of publication of this notification in the Official Gazette, namely:––
In the said notification, in the opening paragraph, for the figures, letters and words "31st day of March, 2025", the figures, letters and words "31st day of March, 2030" shall be substituted.
[No. 92/2025/F. No. 500/Misc./S10(23FE)/FT&TR-II]
BAHNI TELENGA, Under Secy.

Note: The principal notification was published in the Gazette of India, Extraordinary, Part II, section 3, sub-section (ii) vide number S.O. 1889(E), dated the 17th May, 2021 and subsequently amended vide notification number S.O.2848(E), dated the 18th July, 2024.
Uploaded by Dte. of Printing at Government of India Press, Ring Road, Mayapuri, New Delhi-110064
and Published by the Controller of Publications, Delhi-110054.

From when

1 April 2025, retrospectively, except as respects things done or omitted to be done from 1 April 2025 till the date of publication in the Official Gazette.

What to watch

The amendment operates except as respects things done or omitted to be done on and from 1 April 2025 till the date of publication of this notification in the Official Gazette.
Only the opening paragraph's date is substituted; the other conditions in the parent notification stand.
The note records an earlier amendment vide S.O. 2848(E) dated 18 July 2024, so the parent notification must be read as amended twice.

Where you meet it

When the notified fund claims exemption under section 10(23FE) on income from an investment made up to the substituted outer date, and in the investee's withholding position on payments to it.

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. 94/2026 [F. No. 370142/24/2026-TPL] / G.S.R. 646(E) : Income-tax (Second Amendment) Rules, 2026 : Amendment of rule 157 of the Income tax Rules, 2026 to align the definition of the specified fund with rule 114AAB of the Income tax Rules, 1962 — Ministry of Finance 21 July 2026
Notification No. 64 — [भाग II—खण् ड 3(i)] भारत का रािपत्र : असाधारण 7 16 April 2026
Notification No. 63/2026 [F. No. 370142/13/2026-TPL]/ GSR 268(E) — 2 the Gazette of INDIA : Extraordinary [Part Ii—sec. 3(i)] 10 April 2026
Notification No. 62/2026 [F. No. 370142/10/2026-TPL]/ GSR 267(E) — Ministry of Finance 10 April 2026
Notification No. 61/2026 [F. No. 370142/9/2026-TPL] / GSR 266(E) — [भाग II—खण् ड 3(i)] भारत का रािपत्र : असाधारण 3 10 April 2026
Notification No. 60/2026 [F. No. 370142/8/2026-TPL]/ GSR 265(E) — 2 the Gazette of INDIA : Extraordinary [Part Ii—sec. 3(i)] 10 April 2026

← Notification No. 91/2025 [F. No. 500/Misc./S10(23FE)/FT&TR-II] / S.O. 3145(E) · Notification No. 93/2025 [F. No. 500/Misc./S10(23FE)/FT&TR-II] / S.O. 3147(E) →

What a notification is. A notification is made under a power the Act itself gives, and within that power it is law — unlike a circular, which only binds the department. Its reach is the reach of the enabling provision and no wider, and the date it carries decides from when it works.

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

What this is