MINISTRY OF FINANCE
(Department of Revenue)
(CENTRAL BOARD OF DIRECT TAXES)
NOTIFICATION
New Delhi, the 16th August, 2022
(INCOME-TAX)
S.O. 3828(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, INQ Holding LLC
(PAN: AADCI5071P), (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
“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 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
Qatar, 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 Qatar;
(vii) the earnings of the assessee shall be credited either to the account of the Government of Qatar 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 Qatar 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.
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