The Central Board of Direct Taxes (CBDT) under the Ministry of Finance issued Notification No. 84/2025-Income Tax on 11th July 2025, amending an earlier notification (No. 53/2021) related to tax exemptions under Section 10(23FE) of the Income-tax Act, 1961. This section provides income tax exemptions to specified sovereign wealth funds (SWFs) investing in infrastructure and other eligible sectors in India. The amendment extends the existing deadline for availing the exemption from “31st March, 2025” to “31st March, 2030,” granting a five-year extension for qualifying investments. The revised timeline is applicable prospectively from 1st April 2025 and does not affect any prior actions. The original notification was published on 5th May 2021 and was earlier amended on 18th July 2024. This update reflects the government’s continued effort to encourage long-term foreign investment in key development areas by extending the incentive window available to eligible SWFs.
MINISTRY OF FINANCE
(Department of Revenue)
(CENTRAL BOARD OF DIRECT TAXES)
Notification No. 84/2025 – Income Tax | Dated: 11th July, 2025
S.O. 3138(E).— In exercise of the powers conferred by sub-clause (vi) of clause (b) of Explanation 1 to clause (23FE) of section 10 of the Income-tax Act, 1961 (43 of 1961), the Central Government hereby makes the following further amendment in the notification of the Government of India in the Ministry of Finance, Department of Revenue (Central Board of Direct Taxes) (Notification No. 53/2021/F.No. 370142/45/2020-TPL) number S.O. 1761(E), dated the 5th May, 2021 published in the Gazette of India, Extraordinary, Part II, section 3, sub-section (ii), except as respects things done or omitted to be done on and from the 1st April, 2025 till the date of publication of this notification in the Official Gazette, namely:––
In the said notification, in the opening paragraph, for the figures, letters and words “31st day of March, 2025”, the figures, letters and words “31st day of March, 2030” shall be substituted.
[No. 84/2025/F.No. 500/Misc./S10(23FE)/FT&TR-II]
BAHNI TELENGA, Under Secy.
Note: The principal notification was published in the Gazette of India, Extraordinary, Part II, section 3, sub-section (ii) vide e number S.O. 1761(E), dated the 5th May, 2021.and subsequently amended vide notification number S.O.2840(E), dated the 18th July, 2024.
