**Executive Summary**
This notification, S.O. 44(E), issued by the Ministry of Finance on January 5, 2026, specifies Inbar Holding RSC Limited as a specified person for the purpose of clause (23FE) of Section 10 of the Income-tax Act, 1961, regarding eligible investments in India made on or after the date of publication until March 31, 2030. The notification outlines several conditions that the assessee must fulfill to maintain tax exemption. The notification comes into force from the date of its publication in the Official Gazette.
**Key Points / Main Content**
* **Eligibility for Tax Exemption:**
* Inbar Holding RSC Limited is specified as a "specified person" under clause (23FE) of Section 10.
* This specification applies to eligible investments made in India from the date of publication of the notification until March 31, 2030.
* **Conditions for Maintaining Exemption:**
* The assessee must file income tax returns for all relevant years, from the date of investment to liquidation, by the due date under Section 139(1).
* The assessee must intimate investment details made during each quarter within one month from the end of the quarter in Form No. 10BBB as per Rule 2DB.
* The assessee must furnish a certificate in Form No. 10BBC regarding compliance with clause (23FE) from an accountant as defined in Section 288, according to Rule 2DB.
* The assessee must maintain a segmented account of income and expenditure related to the investment.
* The assessee must continue to be regulated under the laws of Abu Dhabi, the United Arab Emirates, or both.
* The assessee is responsible for administering or investing assets to meet statutory obligations and defined contributions for employee benefit plans.
* The assessee's earnings and assets should be used solely for statutory obligations and defined contributions, barring payments to creditors/depositors for loans taken for purposes other than making investment in India.
* The assessee must not have any loans or borrowings for making investment in India.
* The assessee must not participate in the day-to-day operations of the investee, excluding monitoring mechanisms including the right to appoint directors.
* **Violation and Effective Date:**
* Violation of any specified conditions renders the assessee ineligible for tax exemption.
* The notification takes effect from the date of its publication in the Official Gazette.
**Impact Analysis**
**Stakeholder: Inbar Holding RSC Limited**
* **Impact:**
* Inbar Holding RSC Limited has been specified as a "specified person" for tax exemption under specific conditions for eligible investments in India. They will need to ensure that all conditions outlined are followed and continue to be met during their operation. Non-compliance may lead to losing this exemption.
* **Action Required:**
* Ensure compliance with all listed conditions to maintain tax exemption eligibility.
* File necessary returns, reports, and certificates as specified (Form 10BBB, Form 10BBC).
* Maintain proper records and accounts for the investment.
**Stakeholder: Ministry of Finance/ Central Board of Direct Taxes (CBDT)**
* **Impact:**
* The ministry has issued a new regulation that provides clarity on the conditions to be met by specified persons such as Inbar Holding RSC Limited, in order to be eligible for tax exemptions. This places an enforcement burden on this organisation.
* **Action Required:**
* Enforce and monitor compliance with the specified conditions.
* Ensure proper implementation of the notification.
**Stakeholder: Investors and Beneficiaries of Inbar Holding RSC Limited**
* **Impact:**
* The assets are for meeting statutory obligations and defined contributions for participants or beneficiaries of the mentioned funds or plans.
* **Action Required:**
* No specific action required, but continued monitoring of the pension fund's compliance is suggested.
Key Entities Referenced
Income-tax Act, 1961: The primary law being referenced and amended by this notification.
Section 10(23FE): Specific section of the Income-tax Act that this notification addresses, concerning tax exemption for specified pension funds.
Central Board of Direct Taxes (CBDT): The regulator issuing the notification concerning income tax.
Inbar Holding RSC Limited: The specific pension fund being granted specified person status in the notification.
New Delhi: Location where the notification was issued
[भाग II—खण्ड 3(ii)] भारत का रािपत्र : असाधारण 3
MINISTRY OF FINANCE
(Department of Revenue)
(CENTRAL BOARD OF DIRECT TAXES)
NOTIFICATION
New Delhi, the 5th January, 2026
(INCOME-TAX)
S.O. 44(E).— In exercise of the powers conferred by sub-clause (iv) of clause (c) of the Explanation 1 to
clause (23FE) of section 10 of the Income-tax Act, 1961 (43 of 1961) (hereinafter referred to as the “Act”), the Central
Government hereby specifies the pension fund, namely, Inbar Holding RSC Limited (PAN: AAGCI2029C),
(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:-
(i) the assessee shall file return of income, for all the relevant previous years falling within the period beginning
from the date in which the said investment has been made and ending on the date on which such investment
is liquidated, on or before the due date specified for furnishing the return of income under sub-section (1)
of section 139 of the Act;
(ii) 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. 10BBB, as per the provisions of clause (v) of rule
2DB of the Income-tax Rules, 1962;
(iii) the assessee shall furnish along with such return a certificate in Form No.10BBC in respect of compliance
to the provisions of clause (23FE) of section 10 of the Act, during the financial year, from an accountant as
defined in the Explanation below sub-section (2) of section 288 of the Act, as per the provisions of clause
(vi)of rule 2DB of the Income–tax Rules, 1962;
(iv) the assessee shall maintain a segmented account of income and expenditure in respect of such investment
which qualifies for exemption under clause (23FE) of section 10 of the Act;
(v) the assessee shall continue to be regulated under the laws of the Government of Abu Dhabi, or the
Government of the United Arab Emirates, or both;
(vi) 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;
(vii) 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 (vi) 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 or borrowing [as defined in sub-clause (b) of clause (ii) of
Explanation 2 to clause (23FE) of section 10 of the Act] taken for the purposes other than for making
investment in India;
(viii) the assessee shall not have any loans or borrowings [as defined in sub-clause (b) of clause (ii) of
Explanation 2 to clause (23FE) of section 10 of the Act], directly or indirectly, for the purposes of making
investment in India; and
(ix) the assessee shall not participate in the day-to-day operations of investee [as defined in clause (i) of
Explanation 2 to clause (23FE) of section 10 of the 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 as stipulated in the said clause (23FE) of section 10 of the Act and this notification
shall render the assessee ineligible for the tax exemption.
3.This notification shall come into force from the date of its publication in the Official Gazette.
[Notification No.1/2026/No. 500/PF6/S10(23FE)/FT&TR-II (2)]
SYAMA SAJI, Under Secy.
Uploaded by Dte. of Printing at Government of India Press, Ring Road, Mayapuri, New Delhi-110064
and Published by the Controller of Publications, Delhi-110054.