Section 10(23FBC) of the 1961 Act → Schedule VI, Sl. 9 of the 2025 Act
Unit holders of a specified fund.
Quick answer
Section 10(23FBC) of the Income-tax Act, 1961 corresponds to Schedule VI, Sl. 9 of the Income-tax Act, 2025. Relationship: Revised. Correspondence verified against both Acts.
How it works
What a unit holder receives from a specified fund, and the gain on transferring its units, are left out of the unit holder’s income.
Example
A non-resident redeems units of a qualifying GIFT IFSC Category III fund at a gain: no Indian tax.
What you need to do
Non-resident investor: no Indian tax on these amounts; if Rule 157 is met, no PAN is needed either. Fund: keep its specified fund status.
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(23FBC)(23FBC) any income accruing or arising to, or received by, a unit holder from a specified fund or on transfer of units in a specified fund. Explanation.—For the purposes of this clause, the expressions— (a) "specified fund" shall have the same meaning as assigned to it in clause (c) of the Explanation to clause (4D); (b) "unit" means beneficial interest of an investor in the fund and shall include shares or partnership interests; Downloaded/Printed on 5/22/26, 5:26 PM from www.incometaxindia.gov.in Income Tax Department Ministry of Finance, Government of India …
2025 · Schedule VI, Sl. 99. Any income accruing or arising to, or received from a specified fund or on transfer of units in a specified fund. A unit holder of a specified 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.