The Central Board of Direct Taxes (CBDT) has issued the Income-tax (Twenty-Fifth Amendment) Rules, 2025, through a notification dated September 1, 2025, published in the Gazette of India. The amendment, made under the powers conferred by Section 295 of the Income-tax Act, 1961, relates to clause (23FE) of Section 10, which provides tax exemptions for certain notified funds such as sovereign wealth funds and pension funds.
As per the amendment, several timelines under Rule 2DCA of the Income-tax Rules, 1962 have been extended:
- References to the financial years 2024-25 have been substituted with 2030-31.
- References to the financial years 2025-26 have been substituted with 2031-32.
- Similarly, in the explanation clauses, the year 2024 has been replaced with 2030.
The move essentially provides a six-year extension for eligible entities to avail of the tax exemption benefits under Section 10(23FE). This step is expected to give long-term certainty to sovereign wealth funds, pension funds, and similar notified investors, encouraging greater foreign investment in infrastructure and priority sectors in India.
This amendment follows the last modification of the Income-tax Rules, 1962, vide Notification G.S.R. 566(E) dated August 21, 2025.
Official copy of the notification has been attached
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