On July 11, 2025, the Central Board of Direct Taxes (CBDT) issued multiple notifications extending the tax exemption period under section 10(23FE) of the Income-tax Act, 1961 for several foreign sovereign wealth and pension funds investing in India. These amendments uniformly extend the original exemption deadline from March 31, 2025, to March 31, 2030, granting a five-year extension for continued tax benefits on eligible investments.
Notification No. 74/2025 amends Notification No. 89/2020 to extend the exemption for MIC Redwood 1 RSC Limited, Abu Dhabi. Notification No. 75/2025 amends Notification No. 33/2021 to extend benefits for Norfund, the sovereign wealth fund of the Government of Norway. Similarly, Notification No. 76/2025 amends Notification No. 34/2021 for the Canada Pension Plan Investment Board.
Further, Notification No. 93/2025 extends the exemption for the School Employees Retirement System of Ohio under Notification No. 130/2021. Notification No. 94/2025 amends Notification No. 84/2021 for 2726247 Ontario Inc., and Notification No. 97/2025 amends Notification No. 111/2021 for 2452991 Ontario Limited.
These extensions reaffirm the Indian government’s commitment to facilitating long-term foreign capital inflows through a stable tax regime for eligible global investors in infrastructure and related sectors.
CBDT Notification No. 74/2025 dated July 11, 2025:
The Central Government, under powers granted by the Income-tax Act, 1961, has amended Notification No. 89/2020 to extend the tax exemption period for the sovereign wealth fund, MIC Redwood 1 RSC Limited, Abu Dhabi, UAE. This fund is recognized as a specified person under clause (23FE) of section 10 for its investments in India. The amendment changes the original exemption end date from 31st March 2025 to 31st March 2030, thereby granting a five-year extension.
CBDT Notification No. 75/2025 dated July 11, 2025:
The Central Government has amended Notification No. 33/2021 to extend the tax exemption period under section 10(23FE) of the Income-tax Act, 1961 for the sovereign wealth fund, Norfund, Government of Norway. Norfund is recognized as a specified person for its investments in India. This amendment changes the original exemption deadline from 31st March 2025 to 31st March 2030, thereby granting a five-year extension, applicable to actions from 1st April 2025 until the date of this notification’s publication.
CBDT Notification No. 76/2025 dated July 11, 2025:
The Central Government has amended Notification No. 34/2021 to extend the tax exemption period under section 10(23FE) of the Income-tax Act, 1961 for the Canada Pension Plan Investment Board. Recognized as a specified person for its eligible investments in India, the amendment updates the exemption validity from 31st March 2025 to 31st March 2030. This extension applies to actions from 1st April 2025 up to the date of publication of this notification, providing continued tax benefits for the pension fund’s Indian investments.
CBDT Notification No. 93/2025 dated July 11, 2025:
The Central Government, under powers granted by the Income-tax Act, 1961, has amended Notification No. 130/2021 to extend the validity period for the specified pension fund, the School Employees Retirement System of Ohio. This fund is recognized as a “specified person” under clause (23FE) for eligible investments made in India. The amendment changes the original deadline from 31st March 2025 to 31st March 2030, allowing the fund to continue availing tax exemption benefits on qualifying investments until the new date.
CBDT Notification No. 94/2025 dated July 11, 2025:
The Central Government has amended Notification No. 84/2021 under the Income-tax Act, 1961, to extend the tax exemption eligibility for the pension fund 2726247 Ontario Inc. This fund is specified as a “specified person” under clause (23FE) for its eligible investments in India. The amendment changes the original deadline from 31st March 2025 to 31st March 2030, thereby allowing the fund to continue availing tax benefits on its qualifying investments in India until the extended date.
CBDT Notification No. 97/2025 dated July 11, 2025:
The Central Government has amended Notification No. 111/2021 under the Income-tax Act, 1961, to extend the tax exemption period for the pension fund 2452991 Ontario Limited. This fund is designated as a “specified person” under clause (23FE) for its eligible investments in India. The amendment updates the original deadline from 31st March 2025 to 31st March 2030, thereby allowing the pension fund to continue receiving tax benefits on qualifying investments in India until the revised date.
The All Notifications can be accessed at: https://a2ztaxcorp.com/wp-content/uploads/2025/07/CBDT-NN-737475939497_11.07.2025.pdf
