Central Board of Direct Taxes (CBDT) has issued Circular No. 11 of 2025, dated 2 September 2025, modifying Circular No. 9 of 2022 relating to clause (23FE) of section 10 of the Income-tax Act, 1961. Clause (23FE) provides tax exemption for income of certain investment funds, including Sovereign Wealth Funds and Pension Funds, subject to specified conditions. The Finance Act, 2025 amended this clause to extend the deadline for making qualifying investments from 31 March 2025 to 31 March 2030, effective from 1 April 2025. Accordingly, the earlier references to the date “31.03.2024” in the original circular, including in its opening paragraph and in paragraphs 4.6.2 and 4.6.3, are now to be read as “31 March 2030.” This modification aligns the earlier issued guidelines with the updated statutory timeline. The circular has been circulated to senior officials of the Ministry of Finance, the Comptroller and Auditor General of India, the Institute of Chartered Accountants of India, and other concerned authorities for necessary action and dissemination.
F.No.370142/32/2025-TPL
Government of India
Ministry of Finance
Department of Revenue
Central Board of Direct Taxes (TPL Division)
Circular No. 11 of 2025-Income Tax | Dated: 02 September, 2025
Sub:- Modification to Circular No. 9 of 2022 (F. No.370142/2/2022-TPL) dated 09.05.2022 of CBDT-reg.
Reference is invited to Circular No. 9 of 2022 (F.No.370142/2/2022-TPL) dated 09.05.2022 of Central Board of Direct Taxes (the ‘Board’) vide which guidelines under clause (23FE) of section 10 of the Income-tax Act, 1961 (the Act) were prescribed.
2. Clause (23FE) of section 10 of the Act was amended, vide Finance Act, 2025, so as to extend the date of investment under the said clause from 31st day of March, 2025 to 31st day of March, 2030. The said amendment is effective from the 1St day of April, 2025.
3. In view of the above, reference to the date 31.03.2024 in the opening para and to the date 31st March, 2024 in paras 4.6.2 and 4.6.3 of the said circular, shall be read as 31st March, 2030 with effect from the Pt day of April, 2025.
(Rohit Singh)
Under Secretary (TPL-I)
CBDT, New Delhi
Copy to the:
1. PS/OSD to FM/ PS/OSD to MoS(F).
2. PS to the Finance Secretary.
3. PS to the Revenue Secretary.
4. Chairman and Members, CBDT.
5. Joint Secretaries/ CsIT/Directors/Deputy Secretaries/Under Secretaries, CBDT.
6. C&AG of India (30 copies).
7. JS & Legal Advisor, Ministry of Law & Justice, New Delhi.
8. Institute of Chartered Accountants of India.
9. CIT (M&TP), Official Spokesperson of CBDT.
10. Principal DGIT (Systems) for uploading on the departmental uthsite.
(Rohit Singh)
Under Secretary (TPL-I)
CBDT, New Delhi
