Gazette Tracker
Gazette Tracker

Core Purpose

The Central Government specifies the Social Protection Fund (SPF) as a 'specified person' for eligible investments in India under the Income-tax Act, 2025, subject to various conditions for tax exemption.

Detailed Summary

The Ministry of Finance, Department of Revenue, Central Board of Direct Taxes, issued Notification S.O. 3890(E) on July 15, 2026, exercising powers under Schedule V [Table: Sl. No. 7. Note 5(a)(iii)(D)] read with section 11 of the Income-tax Act, 2025. This notification specifies the pension fund, Social Protection Fund (SPF) (PAN: ABOCS3010J), as a 'specified person' for eligible investments made in India from July 15, 2026, until March 31, 2030. This specification is contingent upon the fulfillment of several conditions, including the SPF filing income returns for all relevant previous years and furnishing a compliance certificate in Form 176 from an accountant (as defined in section 515(3)(b)) along with such returns, as per clause 1(h) of rule 282 of the Income Tax Rules, 2026. Additionally, SPF must intimate investment details quarterly in Form No. 175, as per clause 1(g) of Rule 282 of the Income Tax Rules, 2026, and maintain a segmented account of income and expenditure for investments qualifying for exemption under Schedule V (Table. Sl No.7) of the Income-tax Act, 2025. The SPF must remain regulated under the laws of the Government of Oman and ensure its earnings and assets are used solely for meeting statutory obligations and defined contributions for participants or beneficiaries of funds or plans providing retirement, social security, employment, disability, or death benefits, without benefiting any other private person, barring payments to creditors or depositors for loans taken for purposes other than investment in India. The fund is explicitly prohibited from having any loans or borrowings (as defined in Schedule V [Table: Sl. No. 7. Note 5(c)] to the said Act) for the purpose of making investments in India and must not participate in the day-to-day operations of investees (as defined in Schedule V [Table: Sl. No. 7. Note 5(a)(iii)(C)]), though monitoring mechanisms like appointing directors are permitted. Violation of any conditions stipulated in Schedule V [Table: Sl. No. 7] of the Income-tax Act, 2025, or this notification will render the assessee ineligible for the tax exemption. The notification became effective upon its publication in the Official Gazette on July 15, 2026.

Full Text

REGD. No. D. L.-33004/99 The Gazette of India CG-DL-E-15072026-274523 EXTRAORDINARY PART II—Section 3—Sub-section (ii) PUBLISHED BY AUTHORITY No. 3727] NEW DELHI, WEDNESDAY, JULY 15, 2026/ASHADHA 24, 1948 [भाग II-खण्ड 3(ii)] THE GAZETTE OF INDIA : EXTRAORDINARY MINISTRY OF FINANCE (Department Of Revenue) (CENTRAL BOARD OF DIRECT TAXES) NOTIFICATION New Delhi, the 15th July, 2026 (INCOME-TAX) S.O. 3890(E). — In exercise of the powers conferred by Schedule V [Table: Sl. No. 7. Note 5(a)(iii)(D)] read with section 11 of the Income-tax Act,2025 (hereinafter referred to as the said Act), the Central Government hereby specifies the pension fund, namely, Social Protection Fund(SPF) (PAN: ABOCS3010J) (hereinafter referred to as the assessee) as the specified person for the purposes of the said clause in respect of the eligible investment made by it in India on or after the date of publication of this notification in the Official Gazette but on or before the 31st day of March, 2030 (hereinafter referred to as the said investments) subject to the fulfilment of the following conditions, namely:- (a) the assessee shall file returns of income, for all relevant previous years falling in the period beginning from the date on which an eligible investment has been made, and ending on the date on which such investment is liquidated, on or before the due date specified under section 263(1)(c) of the said Act and furnish a compliance certificate in Form 176 from an accountant as defined in section 515(3)(b) along with such return, as per the provisions of clause 1(h) of rule 282 of the Income Tax Rules, 2026; (b) the assessee shall intimate the details in respect of each investment made by it in India during the quarter within one month from the end of the quarter in Form No. 175, as per provisions of clause 1(g) of Rule 282 of the Income Tax rules, 2026; (c) the assessee shall maintain a segmented account of income and expenditure in respect of such investments which qualifies for exemption under Schedule V(Table. Sl No.7) of the said Act. (d) the assessee shall continue to be regulated under the laws of the Government of Oman; (e) the assessee shall be responsible for administering or investing the assets for meeting the statutory obligations and defined contributions of one or more funds or plans established for providing retirement, social security, employment, disability, death benefits or any similar compensation to the participants or beneficiaries of such funds or plans, as the case may be; (f) the earnings and assets of the assessee should be used only for meeting statutory obligations and defined contributions for participants or beneficiaries of funds or plans referred to in clause (e) and no portion of the earnings or assets of the pension fund inures any benefit to any other private person; barring any payment made to creditors or depositors for loan taken or borrowing (as defined in Schedule V [Table: Sl. No. 7. Note 5(c)] to the said Act) for the purposes other than for making investment in India; (g) the assessee shall not have any loans or borrowings (as defined in Schedule V [Table: Sl. No. 7. Note 5(c)] to the said Act), directly or indirectly, for the purposes of making investment in India; and (h) the assessee shall not participate in the day-to-day operations of investee (as defined in Schedule V [Table: Sl. No. 7. Note 5(a)(iii)(C)] to the said Act) but the monitoring mechanism to protect the investment with the investee including the right to appoint directors or executive director shall not be considered as participation in the day- to-day operations of the investee. 2. Violation of any of the conditions stipulated in Schedule V [Table: Sl. No. 7] of said Act and this notification shall render the assessee ineligible for the tax exemption. 3. This notification shall come into force on the date of its publication in the Official Gazette. [No. 84/2026/F.No. 500/PF-15/S10(23FE)/FT&TR-II] SYAMA SAJI, Under Secy.

Never miss important gazettes

Create a free account to save gazettes, add notes, and get email alerts for keywords you care about.

Sign Up Free