FME Regulatory Intelligence, Learning & Practice · IFSCA (Fund Management) Regulations, 2025

What is representative assessee?

In one sentence

A person taxed on income received on behalf of someone else, such as a trustee taxed on a trust’s income for its beneficiaries.

An everyday analogy

Like a guardian who files tax for a child’s income.

How it flows

Trust earns incomeTrustee taxed for the investorsTax reflected in the NAV

A real example

The trustee of a SEBI Category III AIF pays tax on the fund’s income on behalf of its investors.

Why it matters

It explains why Category III fund income is taxed inside the fund.

How it differs

Under pass-through, the investor is taxed directly; under representative assessment, the trustee is.

What the law says

Section 303(1)(d)
(d) in respect of income which a trustee appointed under a trust declared by a duly executed instrument in writing whether testamentary or otherwise [including any wakf deed which is valid under the Mussalman Wakf Validating Act, 1913 (6 of 1913)] receives or is entitled to receive on behalf or for the benefit of any person, such trustee or trustees;

Income-tax Act, 2025 as amended by the Finance Act, 2026 · text as notified, amendment footnote numbers omitted · checked 24 October 2026 · Official text

Test yourself: Who pays tax on a Category III AIF’s income?
Show answer

The trustee, as representative assessee of the investors.

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Prashant Kumar

Meet the expert

CS Prashant Kumar

Company Secretary & Compliance Officer
Global Horizons Capital Advisors (IFSC) Private Limited — an IFSCA-licensed investment banker

13+ years of experienceFCS Fellow member, ICSIAuthor Audit Under Fire

Published in The Chartered Accountant (Jun 2025, Jan 2025, Mar 2024) and Chartered Secretary (Aug 2023)

Prashant Kumar is a seasoned Company Secretary and corporate governance strategist with more than 13 years of experience advising large corporates, promoter-led groups and global businesses on compliance, regulatory risk and board governance. In GIFT IFSC, the IFSCA regime is his day job rather than a research topic.