Section 10(4D) of the 1961 Act → Schedule VI, Sl. 1 of the 2025 Act
Specified fund: transfers on an IFSC exchange.
Quick answer
Section 10(4D) of the Income-tax Act, 1961 corresponds to Schedule VI, Sl. 1 of the Income-tax Act, 2025. Relationship: Revised. Correspondence verified against both Acts.
How it works
A specified fund’s gains on transfers made on an IFSC stock exchange, paid in convertible foreign exchange, are left out of its income, to the extent they belong to non-residents’ units.
Example
A GIFT IFSC specified fund sells securities on an IFSC stock exchange for US dollars: those gains are not taxed, for the non-residents’ share.
What you need to do
Fund: track the non-resident share of units to apply the exemption. Investor: no action.
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(4D)(4D) any income accrued or arisen to, or received by a specified fund as a result of transfer of capital asset referred to in clause (viiab) of section 47, on a recognised stock exchange located in any International Financial Services Centre and where the consideration for such transaction is paid or payable in convertible foreign exchange or as a result of transfer of securities (other than shares in a company resident in India) or any income from securities issued by a non-resident (not being a permanent establishment of a non-resident in India) and where such income otherwise does not accrue or arise in India or any income from …
2025 · Schedule VI, Sl. 11. Any income accrued or arisen to, or received, as a result of transfer of capital asset referred to in section 70(1)(r) where such transfer takes place on a recognised stock exchange located in any International Financial Services Centre. Any specified fund. (a) Consideration is paid or payable in convertible foreign exchange; (b) Income shall not be included in the total income to the extent such income is attributable to–– (i) units held by non-resident (not being the permanent establishment of a non-resident in India); or (ii) the investment division of offshore banking unit; and (c) The income exempt shall be computed in such manner …
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.