India's Central Board of Direct Taxes (CBDT) has issued Circular No. 9 of 2022, providing guidelines on the application of clause (23FE) of Section 10 of the Income Tax Act to address difficulties regarding the interpretation or implementation of the provisions of the said clause. Section 10 (23FE) was added as part of the Finance Act 2020 to provide a 100% tax exemption on interest, dividend, and capital gains income in respect of investments made by sovereign wealth funds, pension funds, e…