Business-Blog
19, Nov 2025

Over the last decade, India has been trying to build highways faster, upgrade ports, modernise logistics, and expand renewable energy at an unprecedented pace. But large-scale infrastructure requires long-term capital, and domestic banks alone cannot fuel this demand. This is where Infrastructure Debt Funds (IDFs) were introduced — to attract patient, low-risk capital from institutions, pension funds, sovereign investors, & high-net-worth individuals.

To make IDFs attractive, the government created a strong tax incentive:
Section 10(47) — a clean, blanket tax exemption for income earned by notified IDFs.

At its core, Section 10(47) is simple:
If a fund qualifies as an Infrastructure Debt Fund, & is officially notified by the CBDT (Central Board of Direct Taxes), any income it earns becomes fully exempt from income tax.

This includes:

  • rental income from infrastructure assets,
  • interest on debt instruments,
  • capital gains from infrastructure investments,
  • and other earnings that flow into the IDF structure.

The idea is straightforward — reduce the tax burden so more capital flows into infrastructure projects that India urgently needs.


What Section 10(47) Actually Says

Section 10(47) provides an exemption for any income of a business trust, being an Infrastructure Debt Fund, provided it is notified by the government.

This includes:

  • any income of a business trust,
  • income of certain infrastructure debt funds,
  • income of an IDF set up under Rule 2F,
  • and income from transactions that would normally be treated as “transfer” but are specifically exempted here.

To illustrate, one of the most recognised funds — L&T Infra Debt Fund — was notified by CBDT as a valid Infrastructure Debt Fund eligible for the Section 10(47) exemption. Similar notifications exist for other approved IDFs as well.


Why This Exemption Exists — The Policy Logic

Infrastructure investment typically spans 20–30 years, and investors prefer stability, predictable returns, & minimum tax leakage. Without a tax incentive, IDF returns would drop sharply, making the instrument unattractive.

Section 10(47) achieves three policy goals:

  1. Encourage long-term capital inflow

By exempting income of IDFs, the government makes Indian infrastructure more appealing to global & domestic investors.

  1. Reduce project financing costs

Infrastructure companies borrow at high interest rates. IDFs provide debt at competitive rates because their income is tax-free."

  1. Strengthen India’s infrastructure roadmap

Whether it’s expressways, airports, metros, or renewable energy parks — IDFs help speed up project execution by easing financial pressure.

Also ReadGuide to Tax Exemption for Notified Entities


What Exactly Qualifies as an Infrastructure Debt Fund?

The Income Tax Act doesn’t exempt every fund investing in infrastructure — the exemption applies only when:

  • The fund is set up as per Rule 2F,
  • It is notified by the Government,
  • It qualifies as a business trust,
  • And it satisfies compliance, governance, & investment rules set by RBI, SEBI, and CBDT.

Only then can Section 10(47) be applied.


How Section 10(47) Helps Investors and the Economy

For investors, the biggest advantage is clear — tax-free income.

For the economy, the benefits are broader:

  • More funds become available for infrastructure financing.
  • Lower borrowing costs improve project viability.
  • Private participation in public infrastructure increases.
  • Domestic savings get channelled into productive assets.
  • Foreign investment flows into long-term nation-building sectors.

The exemption also brings India closer to global norms, where infrastructure funds often enjoy tax neutrality to promote capital inflow.


Examples to Understand It Better

Example 1 — IDF earns interest income

A notified Infrastructure Debt Fund invests ₹500 crore in toll road bonds. It receives interest income.
👉 Under Section 10(47), this interest income is fully exempt.

Example 2 — IDF earns capital gains

An IDF sells its stake in a renewable energy project & earns long-term capital gains.
👉 Again, exempt under Section 10(47).

Example 3 — Rent from directly owned real estate

Some IDFs may own infrastructure assets that generate rental income, such as warehouses.
👉 Such rental income too is exempt, provided the IDF qualifies as per Rule 2F.


Impact on Taxability for Investors

A common question taxpayers ask is:
“If the IDF’s income is exempt, what about the income distributed to investors?”

Well — that depends on the structure.
In most cases, the IDF’s income is exempt at the fund level, but distributions may be taxable or exempt depending on the type of income & the investor category.

However, the core benefit remains:

IDFs retain earnings without paying tax, which enhances returns for investors.


Connection With Other Exemptions in the Income Tax Act

Section 10(47) is often discussed alongside other exempt-income provisions, such as those for:

  • charitable trusts,
  • scientific research,"
  • notified bodies under Section 10(46A),
  • and specialised funds serving public interest.

But unlike many exemptions that have conditions or ceilings, Section 10(47) is clean & straightforward — the income of the fund is exempt as long as it remains a notified IDF.

Also ReadWhy UPSC Members Enjoy Zero Tax on These Allowances


Why Tax Professionals Should Track Section 10(47)

For CAs, CFOs, wealth managers, and policy analysts, this section is important because:

  • IDFs are becoming a major investment vehicle,
  • Infrastructure spending is rising each year,
  • More funds are getting notified by CBDT,
  • And tax-exempt instruments must be understood correctly for compliance & advisory work.

Final Thoughts

Section 10(47) of the Income Tax Act may look like a small clause, but its impact is massive. By exempting all income of a notified Infrastructure Debt Fund, the law supports India’s infrastructure ambitions & unlocks capital for projects that shape the country’s future. If you're an investor, corporate, or fund manager evaluating IDF-based structures, understanding this exemption can make a real difference to your tax strategy and long-term returns.

Need Expert Help With Infrastructure Taxation or Fund Structuring? Talk to a qualified CA at CallMyCA.com — clear guidance, compliant structures, & real-world tax strategies are just one click away.