Section 10(23FBA) of the 1961 Act → Schedule V, Sl. 1 of the 2025 Act
Exemption for an investment fund.
Quick answer
Section 10(23FBA) of the Income-tax Act, 1961 corresponds to Schedule V, Sl. 1 of the Income-tax Act, 2025. Relationship: Revised. Correspondence verified against both Acts.
How it works
The fund itself pays no tax on its income other than business income; that income passes to the investors.
Example
A fund’s capital gains are not taxed at the fund; its business income is.
What you need to do
Fund: compute and pay tax only on business income. Investor: no action on this provision itself.
What changed?
- The rule has moved out of a clause of section 10 into a schedule table that sets out the income, the eligible persons and the conditions.
- Read the complete new provision, including its conditions, exceptions and related provisions, when applying it.
The two texts, side by side
1961 · Section 10(23FBA)(23FBA) any income of an investment fund other than the income chargeable under the head "Profits and gains of business or profession";
2025 · Schedule V, Sl. 11. Any income other than the income chargeable under the head “Profits and gains of business or profession”. An investment fund. Nil.
Excerpts end with … where the provision continues. Last reviewed 24 October 2026.
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Meet the expert
CS Prashant Kumar
Company Secretary & Compliance Officer
Global Horizons Capital Advisors (IFSC) Private Limited — an IFSCA-licensed investment banker
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.