Computation of Exempt Income
(a) Infrastructure Development Entities: Entire income is exempt. However, Circular No. 9, dated 09-05-2022, clarified that for hybrid infrastructure entities (with multiple business lines), exemption is available proportionately if ≥ 50% of the total profit before tax (PBT) arises from eligible infrastructure activity. Exempt income will be calculated proportionately to the hybrid entity’s PBT from infrastructure activities to its total PBT.
(b) InVITs: Exemption is available on all income received by the eligible person, including income passed through by the InVIT, irrespective of its taxability in the hands of the trust.
(c) Infrastructure Investment Companies: Exemption is allowed if ≥ 75% of their investments are in infrastructure development entities. Proportionate exemption is computed as per Rule 2DCA.
(d) Infrastructure Finance Companies: Exemption applies if ≥ 90% of lending is to infrastructure development entities. Proportionate computation and reporting are followed as per Rule 2DCA.
(e) Infrastructure AIFs: Exemption is granted if ≥ 50% of investments are in infrastructure entities, investment companies, finance companies, or InVITs, subject to Rule 2DCA compliance.