Category III AIF Taxation in India: A Complete Structure and Rate Guide

Category III Alternative Investment Funds (AIFs) sit in a different tax universe from their Category I and II counterparts. Where Category I and II funds pass income through to investors under Section 115UB of the Income Tax Act, a Category III fund has no statutory pass-through. Tax is computed and paid at the fund level before any distribution reaches an LP. The fund vehicle (trust, company, or LLP) determines how that computation works, and getting the vehicle wrong is not a minor inefficiency: it can cost 10 to 15 percentage points of gross return. This article goes deep on Category III taxation specifically. For the broader AIF taxation overview across all three categories, see Treelife’s AIF taxation guide, and for a full comparison of Category I, II, and III structures, see AIFs in India: framework, types, and regulations.

Why Category III sits outside the Section 115UB framework

Section 115UB of the Income Tax Act, 1961 (now renumbered under the Income Tax Act, 2025) established pass-through treatment for AIFs categorised as investment funds within Explanation 1 to the section. Category I and II AIFs are explicitly included. Category III AIFs are not. The legislative intent was to reserve pass-through for funds with policy-oriented mandates: venture capital, SME lending, infrastructure, and private equity. Category III funds, which may use leverage and complex derivatives strategies, were excluded.

The consequence is structural. When a Category I or II AIF earns capital gains, the character passes to the investor: the investor reports and pays tax at the rate applicable to them. When a Category III AIF earns capital gains, the fund entity pays tax first, and the investor receives a post-tax distribution. The investor does not report the underlying income again, but they also cannot use personal exemptions, set off personal losses, or claim a different rate based on their individual profile.

This is not always disadvantageous. An investor in the 39% slab who holds units in a Category III fund taxed at 35.88% on long-term capital gains has a narrow arbitrage in their favour. A corporate investor taxed at 25.17% at the entity level may actually find the fund-level tax is higher than what they would have paid directly. The net return impact depends on income composition, holding period, and investor profile. What matters is computing it before committing capital, not after.

The Finance Act, 2025 made one material change that affects Category I and II but is worth noting in context. It amended Section 2(14) of the Income Tax Act, 1961 to expressly classify securities held by investment funds under Section 115UB as capital assets. This removes any residual ambiguity about whether a Category I or II fund’s trading activity constitutes business income. Category III funds were not included in this amendment because they are not Section 115UB funds. For Category III, the business income vs capital gains question is still resolved by conduct, strategy, and judicial interpretation. That is precisely why income characterisation inside a Category III fund remains a live structuring decision.

How trust taxation applies to Category III AIFs: sections 160–164 explained

Most Category III AIFs are structured as private trusts. A trust is not a separate assessable entity under the Income Tax Act; instead, the trustee is assessed as a representative assessee under Section 160. The trustee pays tax on behalf of the beneficiaries, and the mechanism for that payment (and the rate at which it applies) depends entirely on whether the trust is determinate or indeterminate under Sections 161 and 164.

A determinate trust is one where the beneficiaries and their respective shares are identifiable. For a Category III AIF trust, this means the identity and proportional interest of each investor are ascertainable, even if not named at the time the trust deed is executed. In a determinate trust, income is taxed as if it were received directly by the beneficiaries: the trustee pays at the rate applicable to the relevant beneficiary or, in the case of business income, at the Maximum Marginal Rate under Section 161(1A).

An indeterminate trust is one where the beneficiaries or their shares cannot be ascertained. Under Section 164(1), the trustee is taxed at the MMR on the entire income of the trust. This is where the AIF industry ran into severe tax exposure for nearly a decade.

The structure of the MMR for FY 2026-27

Component	Rate
Base income tax rate on business income	30%
Surcharge (where income exceeds ₹1 crore, highest bracket applicable to trusts)	37% of base
Health and education cess	4% of (tax + surcharge)
Effective MMR (approx.)	~42.74%

Note: surcharge on capital gains income under Sections 111A, 112, and 112A is capped at 15% regardless of quantum. For a determinate Category III trust earning capital gains, the effective rate on LTCG on listed equity (Section 112A) is approximately 14.25% and not 42.74%. Business income and derivative trading income (classified as profits and gains of business or profession, or PGBP) are not subject to the surcharge cap.

The Equity Intelligence ruling and why it changes structuring conversations

For years, CBDT Circular No. 13/2014 created a near-impossible situation for Category III AIF trusts. The Circular required that the names and beneficial interests of all investors be specified in the original trust deed for the trust to qualify as determinate. If they were not named, the trust was treated as indeterminate and taxed at the full MMR across all income, including capital gains.

The problem was that SEBI (AIF) Regulations, 2012 (specifically Regulations 3, 4, 6, and 7) prohibit an entity from accepting any investment or identifying investors before completing SEBI registration. You cannot name investors in a trust deed executed for the purpose of registration because investors can only be admitted after registration. The Circular imposed a condition that SEBI made structurally impossible to satisfy.

In July 2025, a Division Bench of the Delhi High Court addressed this directly in Equity Intelligence AIF Trust v. CBDT & Anr. (2025:DHC:6170-DB). The Court held that a Category III AIF trust does not become indeterminate merely because investor names are absent from the original trust deed, provided the investors are identifiable and their shares are ascertainable through contribution agreements and unit holdings. The Court invoked the doctrine of impossibility (that law cannot compel a person to do what regulation prohibits) and struck down Paragraph 6 of the Circular, which had created jurisdiction-specific enforcement and allowed the tax department to apply conflicting standards depending on geography.

The key test that the Court confirmed is proportionality-based: once benefits are shared in proportion to investment, any person with reasonable prudence can determine the shares. That satisfies the determinacy requirement under Section 164.

What this ruling means operationally:

• A Category III AIF trust structured with a contribution agreement that clearly identifies each investor’s proportionate interest qualifies as determinate, even at launch with no investor names in the trust deed
• The MMR under Section 161(1A) applies only to business income, not to all income of a determinate trust. Capital gains on investment positions, dividend income, and non-business interest are assessed at the rates applicable to the beneficiaries
• CBDT Circular 13/2014 remains on the books but must be read as construed by the Court: the proportionality test, not the literal deed-naming test, governs determinacy
• Funds operating in jurisdictions outside the Delhi High Court’s jurisdiction should verify whether their jurisdictional High Court has adopted a similar position

This ruling has direct implications for open-ended Category III funds, structures where investors enter and exit frequently. The concern had been that rolling investor admission would continuously render the trust indeterminate. The Court’s proportionality approach addresses this: as long as each investor’s proportionate share is calculable at any point, the trust is determinate. For an assessment of your current structure against the post-Equity Intelligence framework, see our AIF setup service.

How income is characterised inside a Category III fund: the PGBP vs capital gains question

The most consequential tax decision for a Category III fund manager is how the fund’s investment activity is classified: as trading income (PGBP, taxed at MMR on business income) or as investment income (capital gains, taxed at the applicable capital gains rate). This distinction is not made by SEBI categorisation. It is made by the Income Tax Department based on a facts-and-conduct analysis.

No statutory rule determines classification. The courts and the CBDT have developed a set of indicators over decades:

Indicators pointing toward capital gains (investment income):

• Investments held for medium to long periods with the intent of capital appreciation
• Low turnover relative to portfolio size
• Securities held in an “investment” account (separate from a “trading” account in the books)
• Investment philosophy documented in the Private Placement Memorandum (PPM) is long-only or buy-and-hold
• Consistent history of reporting as investment income in prior filings

Indicators pointing toward PGBP (business income):

• High-frequency trading, algorithmic execution, or very short holding periods
• Use of leverage beyond operational requirements
• Derivatives-heavy strategies (futures, options, swaps) where the primary objective is short-term profit
• The fund’s PPM describes the strategy as “active trading” or “market-making”
• Infrastructure for trading (dedicated terminals, algorithmic systems) suggests a business characterisation

For funds running mixed strategies (for instance, a long-short equity book alongside a derivatives overlay) the characterisation may split. The Delhi High Court in Equity Intelligence affirmed the T.A.V. Trust principle: Section 161(1A) applies only to the business income component. Capital gains on investment positions are taxed at the capital gains rate applicable to the beneficiaries, not at the MMR. A fund generating ₹10 crore in derivatives PGBP and ₹15 crore in equity LTCG does not pay MMR on the full ₹25 crore; it pays MMR only on the ₹10 crore PGBP and the applicable capital gains rate on the ₹15 crore LTCG.

Tax rates on Category III fund income by income type (FY 2026-27)

Income type	Rate at fund level	Surcharge cap?
PGBP / business income (including F&O, most derivatives)	~42.74% (MMR)	No
STCG on listed equity (Section 111A)	20% + surcharge + cess	Yes, 15% surcharge cap
LTCG on listed equity above ₹1.25 lakh (Section 112A)	12.5% + surcharge + cess	Yes, 15% surcharge cap
LTCG on other assets (Section 112)	20% + surcharge + cess (with indexation where available)	Yes, 15% surcharge cap
Interest income	Slab rate applicable to the fund entity, or MMR for trusts	No
Dividend income	Slab/MMR, depending on trust determinacy	No

Rates as of FY 2026-27. Verify current rates at incometaxindia.gov.in. Post-Equity Intelligence, capital gains rates for a determinate trust apply at the beneficiary-applicable rate, not automatically at MMR.

What fund-level taxation means for the investor experience

Investors in a Category III fund receive distributions after the fund has already paid tax. This changes the investor’s tax experience in three important ways.

First, personal tax losses cannot be offset against income already taxed at the fund level. If an investor holds personal capital losses from another investment, they cannot use those losses to reduce their tax exposure on Category III distributions. The fund has already settled the liability. This is materially different from Category I and II, where the investor can net losses against passed-through gains.

Second, the investor’s personal exemption thresholds do not apply. The ₹1.25 lakh LTCG exemption under Section 112A, the basic exemption limit for individual investors, slab-rate planning: none of these apply at the investor level for income that has already been taxed at the fund.

Third, Form 64C (the annual statement issued by the AIF to investors) still needs to be reviewed carefully. Even where fund-level tax is paid, investors may have ITR reporting obligations depending on their total income and residential status. For NRI investors, the complexity increases: the fund has paid Indian tax, but the investor’s home country may also want to tax the distribution. Whether a foreign tax credit (FTC) is available in the home country for Indian tax paid at the fund level, as opposed to Indian tax paid directly by the investor, depends on the treaty country’s domestic rules and is not universally settled.

How does DTAA work for NRI investors in a Category III fund?

This is where Category III NRI investor tax gets genuinely complex. For NRI investors in Category I and II AIFs, DTAA benefits are relatively straightforward because income passes through to the investor, who then claims the treaty rate reduction on their TDS and files a Tax Residency Certificate (TRC) and Form 10F before distribution.

For Category III, the fund pays tax under its own PAN. The distribution to the NRI LP is a post-tax cash flow, not a direct income item in the NRI’s hands for Indian tax purposes. Whether the NRI can claim FTC in their home country for Indian tax paid at the fund level depends on whether the home country’s tax authority treats the fund as transparent (look-through to the investor) or opaque (the fund is the taxpayer).

In practice, NRI investors from DTAA jurisdictions such as the UAE, Singapore, or Mauritius should obtain a written tax opinion from a qualified advisor in their home jurisdiction before investing, specifically on whether Indian tax paid by the Category III trust will qualify for credit against home country tax on the same distribution. Do not assume it will simply because a DTAA exists. The TRC and Form 10F mechanism is still relevant where the fund makes any taxable payment directly to the investor before fund-level settlement.

Company and LLP structures as Category III vehicles: the trade-offs

A trust is the dominant Category III vehicle in India, but it is not the only option. Funds have been structured as companies and, less commonly, as LLPs. Each has distinct tax consequences.

Category III as a company

A company-structured Category III AIF is taxed under the normal corporate tax regime. Sections 160–164 do not apply; there is no trust-level determinacy analysis and no MMR exposure on that basis. For AY 2026-27, a domestic company can opt for 22% under Section 115BAA (subject to conditions), 25% if eligible under Section 115BA based on turnover thresholds, or 30% otherwise. Minimum Alternate Tax (MAT) under Section 115JB applies at 15% of book profits for companies not under the concessional regime.

The structural disadvantage is double taxation. Profits are taxed at the company level. Distributions to investors may then be taxed again in the investor’s hands, depending on the mode: dividends are now taxable in the investor’s hands under Section 115BBDA provisions above the threshold, and buybacks have been restructured under Finance Act, 2026. The combined effective rate can exceed the MMR on a trust in scenarios where the investor is in the top slab. For most institutional fund sponsors, the company structure is not preferred unless there are specific commercial reasons: regulatory familiarity with a corporate vehicle, a foreign co-sponsor requiring a company structure, or specific liability protection needs.

Category III as an LLP

An LLP earns income as a business entity and pays tax on its business income at 30% (plus surcharge and cess). Distributions to partners (investors) are exempt under Section 10(2A). The single-layer taxation is structurally appealing: unlike a company, there is no second layer on distribution. The challenge is LP familiarity: most institutional investors in India and globally are comfortable with trust-based AIF structures. An LLP AIF requires investor and counsel comfort with the LLP Act, 2008, and the fund documentation is different from the standard trust-based AIF structures.

The Corporate Laws (Amendment) Bill, 2026 (referred to a Joint Parliamentary Committee as of 23 March 2026) proposes a statutory conversion route for SEBI-registered trust-AIFs to convert to LLPs under a new Section 57A of the LLP Act. This is not yet enacted. Fund managers considering an LLP structure should monitor the Bill’s progress; a conversion route would remove the practical constraint of needing to wind up the trust and relaunch as an LLP.

Vehicle comparison for Category III

Feature	Trust	Company	LLP
MMR exposure on indeterminate income	Yes (mitigated post-Equity Intelligence)	No	No
Double layer of tax on distribution	No	Potential	No
Investor/LP familiarity	High	Medium	Low
Income splitting (PGBP vs capital gains)	Yes, after Equity Intelligence	No (all at corporate rate)	Yes (if income characterised correctly)
Conversion/restructuring flexibility	Limited (statutory route pending)	Standard M&A routes	Statutory route proposed
NISM certification requirement for AMC team	Yes (XIX-C or XIX-E)	Yes	Yes

Common mistakes that cost Category III managers and investors return

1. Treating all Category III income as uniformly subject to MMR

After the Equity Intelligence ruling, this is no longer accurate for determinate trusts. Capital gains on investment positions in a determinate Category III trust are taxed at the applicable capital gains rate, not at MMR. Funds that structured their distributions assuming MMR on all income may have over-withheld tax. Reviewing the actual income composition against the post-Equity Intelligence framework is a worthwhile exercise before the next annual statement.

2. Not aligning the PPM investment strategy with income characterisation

A PPM that describes a “high-frequency active trading strategy” while the fund manager intends to claim capital gains treatment on exits is an inconsistency that the Income Tax Department will exploit in an assessment. The PPM, contribution agreement, investment policy statement, and actual portfolio conduct must be aligned. If the strategy is investment-oriented, say so. If it involves significant F&O activity, build the PGBP tax cost into the fund model from day one.

3. Assuming the Equity Intelligence ruling protects all jurisdictions equally

The Delhi High Court’s ruling is binding within Delhi’s jurisdiction. Other High Courts (including those in Maharashtra, Karnataka, Tamil Nadu, and Telangana) have independently settled the issue in similar directions (Karnataka in India Advantage Fund-VII, Madras in TVS Shriram Growth Fund). But Category III funds registered or assessed in jurisdictions without a settled High Court position should obtain a specific legal opinion, not assume the Delhi ruling applies automatically. Paragraph 6 of the Circular, though read down, nominally reserves the department’s right to take a contrary position where a High Court has not ruled.

4. Neglecting advance tax obligations at the fund level

Because Category III pays tax at the fund level under the trust’s PAN, the fund itself has advance tax obligations under Sections 234B and 234C. Advance tax is payable in four instalments: 15% by 15 June, 45% by 15 September, 75% by 15 December, and 100% by 15 March of the relevant financial year. Funds that pay tax only at year-end are routinely assessed interest on shortfalls. For funds with irregular income timing (driven by portfolio company events, secondary exits, or derivatives settlement) advance tax planning requires quarterly income estimation, not annual.

5. NRI investors assuming the fund’s TDS covers their home country obligation

The fund may pay Indian tax under its PAN, but the NRI investor’s home country does not automatically credit that tax. Whether an FTC claim succeeds depends on the home country’s view of the Category III trust structure. US investors, in particular, face potential PFIC (Passive Foreign Investment Company) classification, which imposes its own regime. Investors from the UK, Canada, and Australia face similar complexity. Each NRI investor should obtain home-country tax advice before committing, not after the first distribution.

What Budget 2026 proposals mean for Category III, and what remains unresolved

The AIF industry’s pre-Budget 2026 submissions to IVCA and the Ministry of Finance included specific proposals on Category III taxation that were not addressed in Finance Act, 2026. These represent the live policy gaps that fund managers should monitor.

The absence of a dedicated Category III framework

Category III funds currently operate under private trust taxation rules that were designed for family trusts, not institutional investment vehicles. There is no Section 115UB equivalent for Category III. The industry has consistently argued for a statutory framework that would tax Category III on a pass-through basis similar to Category I and II, or at minimum provide an election mechanism. This was not addressed in Budget 2026.

Private credit and debt-oriented AIFs: the mutual fund parity argument

Private credit AIFs (many of which are Category II, but some structured as Category III for strategy flexibility) earn interest income taxed at slab or MMR rates of approximately 39–42%. Certain debt-oriented mutual fund schemes that qualify as equity-oriented under technical income composition rules benefit from materially lower capital gains rates. IVCA’s Budget 2026 submission argued this mismatch is economically incoherent and creates a distorted level playing field. The Finance Act, 2026 did not address this.

The income characterisation question for derivatives-heavy funds

F&O income classified as PGBP and taxed at MMR makes certain quantitative and derivatives-based strategies structurally less viable in India compared to offshore structures, particularly GIFT City-based AIFs, which enjoy a concessional rate environment. As GIFT City matures as a fund domicile, the tax gap between a Category III AIF in IFSC and a domestic Category III AIF on F&O income is becoming a structuring consideration that fund managers and their LPs are actively discussing.

The indeterminate trust risk for open-ended funds in non-Delhi jurisdictions

Even after the Equity Intelligence ruling, the statutory provision (Explanation 1 to Section 164) has not been amended. The cure is judicial, not legislative. IVCA has called for a statutory amendment to Section 164 to codify the proportionality test and remove the geographic inconsistency. This was not done in Budget 2026. Open-ended Category III funds registered outside Delhi continue to operate with some residual risk until their jurisdictional High Court settles the point or Parliament amends the provision.

FAQs on Taxability of AIF Category 3 in India

Q: Does a Category III AIF ever get pass-through treatment?
A: Not under the Income Tax Act as it currently stands. Section 115UB applies only to Category I and II AIFs. Category III funds pay tax at the fund level. There is no elective pass-through mechanism available.

Q: What is the MMR for a Category III AIF trust in FY 2026-27?
A: For an indeterminate trust, approximately 42.74%: 30% base rate, 37% surcharge applied to the tax (applicable where income exceeds ₹1 crore at the trust level), plus 4% cess on tax plus surcharge. For a determinate trust, capital gains income is taxed at the capital gains rate applicable to the beneficiaries, not at MMR.

Q: Does the Equity Intelligence ruling apply to my fund if it is registered in Mumbai?
A: The Delhi High Court’s reasoning is persuasive and follows earlier Karnataka and Madras High Court decisions. However, it is technically binding only in Delhi jurisdiction. Funds in Maharashtra should obtain a specific legal opinion, ideally by applying to the relevant ITAT or HC to confirm the position in their jurisdiction.

Q: What is the tax treatment of F&O income inside a Category III fund?
A: Income from futures and options is generally classified as PGBP. For a determinate trust, PGBP is taxed at the MMR under Section 161(1A), approximately 42.74% in FY 2026-27. The surcharge cap applicable to capital gains does not apply to PGBP. Separating the investment book from the derivatives/trading book is critical for accurate tax computation.

Q: Can an NRI investor claim DTAA benefits when investing in a Category III fund?
A: The fund pays Indian tax under its own PAN. The investor receives a post-tax distribution. Whether the investor can claim a foreign tax credit in their home country for the Indian tax paid at fund level depends on the home country’s domestic rules and treaty positions. This is not automatic. NRI investors should obtain a home-country tax opinion before investing.

Q: What documents does an NRI Category III investor need to maintain?
A: PAN (mandatory), Form 64C from the AIF (annual), TRC and Form 10F if making any direct TDS claim, contribution agreement and subscription form, and home-country FTC documentation if claiming credit for Indian tax paid at fund level. FEMA compliance documentation (FEMA declaration, NRE/NRO bank account details) is also required at investment stage.

Q: How is carried interest taxed for a Category III fund manager?
A: Budget 2025 clarified that carried interest is treated as capital gains rather than salary or professional income. The rate depends on the holding period and asset type. For a manager receiving carry from a fund whose primary income is PGBP, the character of the underlying income may affect the carry characterisation. This is an area where individual manager tax advice is necessary.

Q: Can a Category III AIF be open-ended after the Equity Intelligence ruling?
A: Yes. The ruling directly addressed the concern that rolling investor admission renders a trust indeterminate. The proportionality test (shares calculable based on unit holdings and contribution agreements) satisfies Section 164 regardless of investor churn. Open-ended Category III funds should ensure their contribution agreements explicitly capture the proportionality mechanism.

Q: What is Form 64C and who files it?
A: Form 64C is the annual statement issued by the AIF to each investor, detailing income credited or distributed during the financial year, the income head under which it is classified, and TDS details. The AIF manager (or fund administrator) prepares and files Form 64C. Investors use it for their own ITR filings and, where applicable, for FTC claims.

Q: Should I prefer a Category III fund to a PMS for tax reasons?
A: It depends on the investor profile and income type. A PMS passes income directly to the investor, who is taxed at their applicable rate. A Category III fund pays tax at fund level, removing the need for individual income reporting on that portion. For investors in the 42.74% slab, a Category III fund earning capital gains at the determinate trust rate may produce a better post-tax outcome than a PMS with the same gross returns. For corporate investors taxed at 22% or 25%, the fund-level tax may be higher. Model the post-tax, post-fee return for your specific investor profile.

Q: What is the Section 194LBB TDS rate for Category III distributions?
A: Section 194LBB governs TDS on distributions by investment funds under Section 115UB, which applies to Category I and II, not Category III. Category III distributions are made from post-tax income at the fund level. The applicable TDS provision, if any, at the distribution stage depends on the nature of the payment and the recipient’s residential status. Verify with your fund administrator and tax counsel for each distribution.

Q: What is NISM Series-XIX certification and who needs it for a Category III fund?
A: SEBI mandates that at least one key investment personnel (KIP) of every AIF manager hold NISM Series-XIX-C certification (for Category III). The exact requirement (XIX-C for complex strategies, XIX-E for specific sub-categories) should be verified against the current SEBI circular on AIF KIP certification requirements.

Q: Are Category III AIFs eligible for any tax exemptions under IFSCA / GIFT City?
A: GIFT IFSC-based AIFs operating under IFSCA (Fund Management) Regulations, 2022 and the 2025 amendments enjoy a different tax framework. Income earned from investments outside India may attract a concessional rate of 9% on certain income streams, and the F&O income concern for derivatives strategies is substantially reduced. GIFT City is increasingly the preferred domicile for Category III managers running quantitative, derivatives-based, or offshore investor-facing strategies. A detailed comparison of the GIFT City AIF framework versus onshore Category III structuring is a separate analysis.

Q: What advance tax instalments apply to a Category III trust?
A: The standard advance tax schedule under the Income Tax Act: 15% of estimated annual tax liability by 15 June, 45% by 15 September, 75% by 15 December, and 100% by 15 March. Interest under Sections 234B and 234C applies on shortfalls. Category III funds with lumpy income timing (driven by exit events or derivatives settlement cycles) need quarterly income estimates, not annual projections.

Regulatory references:

• Income Tax Act, 1961: Sections 10(23FBA), 111A, 112, 112A, 115BAA, 115BAB, 115JB, 115UB, 160, 161, 161(1A), 164, 164(1), Explanation 1 to Section 164, Sections 234B and 234C
• Finance Act, 2015: Introduction of Section 115UB (pass-through for Category I and II AIFs)
• Finance (No. 2) Act, 2024: Capital gains rate revision effective 23 July 2024 (STCG to 20%, LTCG to 12.5%)
• Finance Act, 2025: Amendment to Section 2(14) classifying securities held by Section 115UB investment funds as capital assets; carried interest clarification as capital gains; effective AY 2026-27
• Finance Act, 2026: TDS consolidation under the Income Tax Act, 2025; buyback taxation restructuring
• SEBI (Alternative Investment Funds) Regulations, 2012: Regulations 3, 4, 6, and 7 (registration and investor admission framework); Category III fund eligibility and investment strategy
• CBDT Circular No. 13/2014 dated 28 July 2014 (indeterminate trust and AIF, read down by Delhi HC)
• Equity Intelligence AIF Trust v. CBDT & Anr. (2025:DHC:6170-DB), Delhi High Court, 29 July 2025
• CIT v. India Advantage Fund-VII (2017 SCC OnLine Kar 6857), Karnataka High Court
• CIT v. TVS Shriram Growth Fund (2020 SCC OnLine Mad 28112), Madras High Court
• CIT v. T.A.V. Trust (264 ITR 52): MMR applies only to business income, not all income of determinate trust
• IFSCA (Fund Management) Regulations, 2022 and 2025 amendments
• Corporate Laws (Amendment) Bill, 2026: proposed Section 57A of the LLP Act (trust-to-LLP conversion; referred to JPC, not yet enacted as of 22 June 2026)

External sources:

• Securities and Exchange Board of India
• Income Tax India
• Reserve Bank of India
• IFSCA
• E-Gazette of India