The Central Board of Direct Taxes vide notification dated 14th January, 2022 has issued the Income tax (1
st Amendment) Rules, 2022. The amendment provides that the income of specified fund attributable to the investment division of an offshore banking unit shall be the total of the following-
- Any income accrued or arisen to, or received by the eligible investment division as a result of transfer of a capital asset referred to in clause (viiab) of section 47 of the Act held by it, 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;
- Any income accrued or arisen to, or received by the eligible investment division as a result of transfer of securities held by it (other than shares in a company resident in India;
- Any income accrued or arisen to, or received by the eligible investment division from securities held by it and 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;
- Any income accrued or arisen to, or received by the eligible investment division from a securitisation trust which is chargeable under the head “profits and gains of business or profession.