Key Update! CBDT Extends Date of Investment Under Section 10(23FE) till March 31, 2030

The Central Board of Direct Taxes (CBDT) under the Government of India has recently issued a Circular No. 11 of 2025 (F.No.370142/32/2025-TPL ) dated September 02, 2025, to notify amendments in a CBDT‘s earlier Circular No. 9 of 2022 (F. No. 370142/2/2022-TPL) dated May 09, 2022, which had issued guidelines related to clause (23FE) of section 10 of the Income-tax Act, 1961. The stated clause is used to provide tax exemption on certain income sources earned by specified investment funds like sovereign wealth funds and pension funds, provided they invest in eligible infrastructure and other notified sectors.

According to the earlier circular, these funds were only allowed to make investments under the said clause up to March 31, 2025. However, after some amendments in Clause (23FE) of section 10 of the Act via the Finance Act, 2025, this deadline was extended till March 31, 2030. This amendment was scheduled to take effect on April 01, 2025.

In conclusion to the said amendment, certain parts of Circular No. 9 of 2022 that referred to an earlier deadline of March 31, 2024, specifically in the opening paragraph and in paragraphs 4.6.2 and 4.6.3, now need to be revised. Those references to March 31, 2024, should now be read as March 31, 2030, with effect from April 01, 2025. This ensures that the guidelines match the new extended investment time limit.