(a)in clause (4D), in the Explanation, in clause (c), in sub-clause (i), in item (I), after the words and figures "Securities and Exchange Board of India Act, 1992, or", the words, brackets and figures "regulated under the International Financial Services Centres Authority (Fund Management) Regulations, 2022, made under the" shall be inserted;(b)for clause (4E), the following shall be substituted with effect from the 1st day ofApril, 2024,—"(4E) any income accrued or arisen to, or received by a non-resident as a result of—(i)transfer of non-deliverable forward contracts or offshore derivative instruments or over-the-counter derivatives; or(ii)distribution of income on offshore derivative instruments, entered into with an offshore banking unit of an International Financial Services Centre referred to in sub-section (1A) of section 80LA, which fulfils such conditions as may be prescribed;";(c)for clause (4G), the following clauses shall be substituted with effect from the 1st day ofApril, 2024, namely:—'(4G) any income received by a non-resident from,—(i)portfolio of securities or financial products or funds, managed or administered by any portfolio manager on behalf of such non-resident; or(ii)such activity carried out by such person, as may be notified by the Central Government in the Official Gazette, in an account maintained with an Offshore Banking Unit in any International Financial Services Centre, as referred to in sub-section (IA) of section 80LA, to the extent such income accrues or arises outside India and is not deemed to accrue or arise in India.Explanation.—For the purposes of this clause, “portfolio manager” shall have the same meaning as assigned to it in clause (z) of sub-regulation (1) of regulation 2 of the International Financial Services Centres Authority (Capital Market Intermediaries) Regulations, 2021, made under the International Financial Services CentresAuthorityAct, 2019;(4H)any income of a non-resident or a Unit of an International Financial Services Centre, as referred to in sub-section (1A) of section 80LA, engaged primarily in the business of leasing of an aircraft, by way of capital gains arising from the transfer of equity shares of domestic company, being a Unit of an International Financial Services Centre, as referred to in sub-section (1A) of section 80LA, engaged primarily in the business of lease of an aircraft which has commenced operations on or before the 31st day of March, 2026:Provided that the provisions of this clause shall apply for capital gains arising from the transfer of equity shares of such domestic company in a previous year relevant to an assessment year falling within the—(a)period of ten assessment years beginning with the assessment year relevant to the previous year in which the domestic company has commenced operations; or(b)period of ten assessment years beginning with the assessment year commencing on the 1st day ofApril, 2024, where the period referred to in clause (a) ends before the 1st day of April, 2034.
