BMC Associates says Replied on 6th June,2026 12:46 PM

No, Section 115BBDA will not apply to the business trust in this case. Where a Special Purpose Vehicle (SPV) distributes dividend to a business trust and the conditions prescribed under Section 115-O(7) are satisfied, such dividend is exempt in the hands of the business trust under Section 10(23FC). Since the income itself is specifically exempt, it does not form part of the total income of the business trust. Further, Section 115BBDA was introduced to tax dividend income exceeding ₹10 lakh in the hands of specified assessees. The provision was originally applicable only to individuals, HUFs, and firms, and not to business trusts. Therefore, even if the dividend amount exceeds ₹10 lakh, Section 115BBDA is not attracted in the hands of the business trust. For businesses seeking guidance on REITs, InvITs, SPVs, and dividend taxation, a qualified chartered accountant Gurgaon professional or a reputed CA firm in Gurgaon can help evaluate the specific tax implications based on the structure and applicable provisions of the Income-tax Act.