IT Act 1961 → 2025 / Section 10(23F)–(23FE)
ExemptionsAIFs, venture capital, REITs/InvITs, unit holders and sovereign wealth funds — 10(23FB) to 10(23FE)
Section 10(23F)–(23FE) of the old Income-tax Act, 1961 · new Schedule V under the Income-tax Act, 2025
New reference Section 11 read with Schedule V (investment funds, business trusts, unit holders)
Applies to FY 2025-26 (AY 2026-27) and earlier years.
Applies from tax year 2026-27 (from 1 April 2026).
| 1961 Act | Subject | 2025 Act |
|---|---|---|
| 10(23FBA) | Investment fund income (other than business) | Schedule V S.No. 1 |
| 10(23FBB) | Unit holder's share of investment fund income | Schedule V S.No. 2 |
| 10(23FC) | Business trust: interest/dividend from SPV | Schedule V S.No. 3 |
| 10(23FCA) | REIT rental income from directly held assets | Schedule V S.No. 4 |
| 10(23FD) | Distributed income in unit holders' hands | Schedule V S.No. 5 |
| 10(23FB) | Venture capital fund/company income | Schedule V S.No. 6 |
| 10(23FE) | Sovereign wealth funds and pension funds investing in infrastructure | Schedule V S.No. 7 |
| 10(23F) | Specified fund income (saving clause) | Schedule V S.No. 8 |
Source: CBDT mapping of sections, Income-tax Act 1961 to Income-tax Act 2025.
Renumbered into Schedule V; the pass-through structure for funds and business trusts continues. Taxation of the distributed income is governed by the business trust and investment fund sections (old 115UA/115UB, now 223/224).
Section 10(23FBA) of the Income-tax Act, 1961 (Investment fund income (other than business)) corresponds to section Schedule V S.No. 1 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).
Section 10(23FBB) of the Income-tax Act, 1961 (Unit holder's share of investment fund income) corresponds to section Schedule V S.No. 2 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).
Section 10(23FC) of the Income-tax Act, 1961 (Business trust: interest/dividend from SPV) corresponds to section Schedule V S.No. 3 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).
Section 10(23FCA) of the Income-tax Act, 1961 (REIT rental income from directly held assets) corresponds to section Schedule V S.No. 4 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).
Section 10(23FD) of the Income-tax Act, 1961 (Distributed income in unit holders' hands) corresponds to section Schedule V S.No. 5 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).
Section 10(23FB) of the Income-tax Act, 1961 (Venture capital fund/company income) corresponds to section Schedule V S.No. 6 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).
Renumbered into Schedule V; the pass-through structure for funds and business trusts continues. Taxation of the distributed income is governed by the business trust and investment fund sections (old 115UA/115UB, now 223/224).