Wednesday , April 1, 2026 |   07:14:07 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
About Us Contact Us Newsletters
 
NEWS FLASH
 
Residency of Binny Bansal of Flipkart-fame - ‘Meaning of Being outside India'! (See TII Edit) TP - Section 92BA(i), governing specified domestic transactions, stands omitted without any saving clause & therefore, is to be treated as non-existent in statute - additions based on Section 92BA quashed: ITAT (See Breaking News) TP - Transfer pricing adjustment on international transaction involving payment of interest to AE is not warranted if assessee has already suo motu disallowed entire interest amount u/s 94B: ITAT (See Breaking News) TPO - In case involving reference to Transfer Pricing Officer, time limit for completing assessment is extended by 12 months as per Section 153(4): ITAT (See Breaking News) I-T - Appeal against a final assessment order lies before the Commissioner Appeals, and not directly before the Tribunal: ITAT (See Breaking News) I-T - Pure error of law based on plausible understanding of law, if income was fully disclosed in accounts and neither concealed nor inaccurately reported, does not attract Sec 271(1)(c): HC (See Breaking News) I-T - Period of limitation for passing final assessment order u/s 144C(13) must be determined by combined and harmonious reading of Section 144C and Section 153: ITAT (See Breaking News) TP - As is trite law, ALP of royalty payments to AEs should be determined using the TNMM method: ITAT (See Breaking News) DTAA - In absence of statutory time stipulation, delayed filing of Form 10F cannot be treated as fatal defect so as to deny treaty benefits, particularly when tax residency & eligibility under DTAA are not in dispute: ITAT (See Breaking News) I-T - Competent Authority shall issue Nil Tax Withholding Certificate within stipulated time, if delay will practically render assessee's case infructuous and will be of no avail as F.Y will be over: HC (See Breaking News) I-T - Final assessment order passed beyond time limit prescribed u/s 153 is barred by limitation and is invalid, even if internal timelines within Sec 144C procedure were adhered to: ITAT (See Breaking News) DTAA - Since payment for standard transponder services does not involve any secret process, it is not taxable as royalty in India under Treaty: ITAT (See Breaking News) INTL - Expenditure incurred wholly & exclusively for business purpose cannot be disallowed merely because it was not necessary or profitable: ITAT (See Breaking News) I-T - Section 144C and Section 153 are not mutually exclusive but are mutually inclusive and must be read harmoniously: ITAT (See Breaking News) TP - Mere reclassification of Compulsorily Convertible Debentures into equity & debt components under Ind-AS does not alter their intrinsic nature as debt instruments until actual conversion: ITAT (See Breaking News) TP - Addition framed TPO invalid where transaction in question is covered by binding Advance Pricing Agreement between assessee & CBDT as per Section 92CC: ITAT (See Breaking News)
 
TII SEARCH
 
 
   
Home >>
 

CBDT issues clarification regarding definition of 'Fund Manager' under Section 9A(4)(b)
By TII News Service
May 17, 2019 , New Delhi

    

GOVERNMENT OF INDIA
MINISTRY OF FINANCE
DEPARTMENT OF REVENUE
CENTRAL BOARD OF DIRECT TAXES
FOREIGN TAX & TAX RESEARCH - II
FT & TR-V DIVISION
NEW DELHI

CIRCULAR NO

8/2019; Dated: May 10, 2019

Subject: Clarification regarding definition of "Fund Manager" under Section 9A(4)(b) of the Income-tax Act, 1961.

Representations have been received in the Board for inclusion of an Asset Management Company (AMC) approved in accordance with Securities and Exchange Board of India (Mutual Funds) Regulations, 1996 for the purpose of Section of 9A(4)(b) of the Income-tax Act, 1961.

2. The matter has been examined in the Board in consultation with SEBI, SEBI has stated that an AMC is engaged in the activity of fund management of Mutual Funds and hence is in substance, a Fund Manager, and entitled for benefits u/s 9A of the Income-tax Act. Therefore, it is hereby clarified that the phrase "fund manager" in Section 9A(4)(b) of the Income-tax Act includes an AMC as approved by SEBI under the SEBI (Mutual Funds) Regulations, 1996. A notification (No. 27/2019 dated 20th March 2019) has already been issued to include the Securities and Exchange Board of India (Mutual Funds) Regulations, 1996 in the definition of "specified regulations" in Section 9A(9)(e) of the Income-tax Act.

[F. No. 500/182/2018-FT & TR-V]

(Subhash Jangala)
Under secretary (FT&TR-V)

 
 
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI TII
  • DTAA
  • Circulars (I-T Act, 1922)
  • Limited Treaties
  • Other Treaties
  • TIEAs
  • Notifications
  • Circulars
  • Relevant Sections of I-T Rules,1962
  • Instructions
  • Administrative Orders
  • DRP Panel
  • I-T Act, 1961
  • MLI
  • Relevant Portion of I-T Act,1922
  • GAAR
  • MAP
  • OECD Conventions
  • Draft Guidelines
  • DTC Bill
  • Committee Reports
  • FATCA
  • Intl-Taxation
  • Finance Acts
  • Manual on EoI
  • UN Model Taxation
  • Miscellaneous
  • Cost Inflation Index
  • Union Budget
  • Information Security Guidelines
  • APA Annual Report
  • APA Rules
  • Miscellaneous
  • Relevant Sections of Act
  • Instructions
  • Circulars
  • Notifications
  • Draft Notifications
  • Forms
  • TP Rules
  • APA FAQ
  • UN Manual on TP
  • Safe Harbour Rules
  • US Transfer Pricing
  • FEMA Act
  • Exchange Manual
  • Fema Notifications
  • Master Circulars
  • Press Notes
  • Rules
  • FDI Circulars
  • RBI Circulars
  • Reports
  • FDI Approved
  • RBI Other Notifications
  • FIPB Review
  • FEO Act
  • INTELLECTUAL PROPERTY
  • CBR Act
  • NBFC Report
  • Black Money Act
  • PMLA Instruction
  • PMLA Bill
  • FM Budget Speeches
  • Multimodal Transportation
  • Vienna Convention
  • EXIM Bank LoC
  • Manufacturing Policy
  • FTDR Act, 1992
  • White Paper on Black Money
  • Posting Policy
  • PMLA Cases
  • Transfer of Property
  • MCA Circular
  • Limitation Act
  • Type of Visa
  • SSAs
  • EPFO
  • Acts
  • FAQs
  • Rules
  • Guidelines
  • Tourist Visa
  • Notifications
  • Arbitration
  • Model Text
  • Agreements
  • Relevant Portion of I-T Act
  • I-T Rules, 1962
  • Circulars
  • MISC
  • Notification
  • About Us
  • Contact Us
  •  
     
    A Taxindiaonline Website. Copyright © 2010-2025 | Privacy Policy | Taxindiainternational.com Pvt. Ltd. OPC All rights reserved.