S.O. 4893(E).—In exercise of powers conferred by sub-clause (vi) of clause (b) 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 sovereign wealth fund, namely, Norges Bank On

Account Of The Government Pension Fund Global (PAN: AACCN1454E), (hereinafter referred to as “the

assessee”) as the specified person for the purposes of the said clause in respect of the 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, 2024 (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 on 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 get its books of account audited for the previous years referred to in clause (i) by

an accountant specified in the Explanation below sub-section (2) of section 288 of the Act and

furnish the Audit Report in the format annexed as Annexure to this notification herewith at least

one month prior to the due date specified for furnishing the return of income under sub-section (1)

of section 139 of the Act;

 

(iii)

the assessee shall furnish a quarterly statement within one month from the end of each quarter

electronically in Form II as annexed to Circular No 15 of 2020, dated the 22nd July, 2020 with F.

No. 370142/26/2020-TPL, issued by the Ministry of Finance, Department of Revenue, Central

Board of Direct Taxes (Tax Policy and Legislation Division), in respect of each investment made

by it during the said quarter;

 

(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 owned and controlled, directly or indirectly, by the Government of

Norway, and at no point of time should any other person have any ownership or control, directly or

indirectly, in the assessee;

 

(vi)

the assessee shall continue to be regulated under the laws of the Government of Norway;

 

(vii)

the earnings of the assessee shall be credited either to the account of the Government of Norway or

to any other account designated by that Government so that no portion of the earnings inures any

benefit to any private person, barring any payment made to creditors or depositors for loan taken or

borrowing [as defined in sub-clause (a) of clause (ii) of Explanation 2 to clause (23FE) of section

10 of the Act] made for purposes other than for making investment in India;

(viii) the assessee shall not have any loan or borrowing [as defined in sub-clause (a) 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;

(ix)

the asset of the assessee shall vest in the Government of Norway upon dissolution, barring any

payment made to creditors or depositors for loan taken or borrowing for purposes other than for

making investment in India; and

 

(x)

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 any 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.