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Understanding Mutual Fund Taxation


May 4, 2023

When we invest in mutual funds, the profits we make are subject to taxes. The good news though is that, in many cases, mutual fund taxes are  somewhat better (lower) than the regular income tax that we pay. The basic reason for this is that the government considers these profits as a different form of inflows/income compared to regular salary or interest incomes.

Understanding the impact of taxation is important – obviously, since our real returns from an online mutual fund investment is what we get after tax. But, more importantly, understanding taxation will help us design our portfolio in a manner that could potentially reduce our tax burden and increase our ‘post-tax’ returns.

mutual fund taxes

In this article, we will take a look at how such profits are considered, how taxation differs across mutual fund categories, what the actual tax rates are, and such other topics. This article, as in other articles in this series, has been written assuming very little prerequisite knowledge from the reader. Please use the table of contents below to skip sections that you are already familiar with.

How are mutual fund returns treated

Taxation structure – how much to tax, when to tax, what to tax etc – differ by various factors. These factors include the type of mutual fund invested in, the period of investment (how long the units were held before redemption), and the type of returns (capital gains or dividend). We will talk about these actual tax rates for these different structures in a bit. Before that, let’s understand the different factors that determine the structures.

In India, 5 types of income are taxable:

  1. Income from salary
  2. Income from house property (rent)
  3. Income from business/profession (Doctors, Lawyers, chartered accountants etc)
  4. Income from capital gains
  5. Other income (interest income, dividends, lottery winnings etc)

Every one of these sections have different tax treatment. Even within each of these categories, there are specific rules that govern how taxation works. For example, when it comes to salary, we are quite familiar with the ‘slab’ concept wherein different levels of income are taxed differently. In other categories, there are other equivalent rules that govern how taxation works for each of them.

When it comes to mutual fund returns, they will come under one of two sections above – income from capital gains and ‘other income’. 

Capital gains

All the gains that we make in the form of selling something in the market at a profit will be considered as capital gains. In terms of mutual funds, when we make a profit by buying mutual fund units at one NAV and selling at another (hopefully higher) NAV, the difference between the sell amount and the buy amount will be considered as capital gains.

For example, if we invest Rs 1 lakh in a fund by buying 10,000 units at an NAV of Rs 10, and then redeem all 10,000 units several months/years later at an NAV of Rs 25, our redemption amount would be Rs 2.5 lakhs. The profit we made, of Rs 1.5 lakhs would be considered as ‘capital gains’ when we file taxes for the fiscal year (FY) when we make our redemption.

The important thing to note is that when we file our income tax returns, these will be tabulated in a section that is different from other incomes. For example, they will be specified  separately (in ‘Schedule CG’ as opposed to ‘Schedule S’ for salary for example) in the form. And, of course, they will be taxed with rates different from other incomes.

Other income

When we invest in mutual funds, we could invest either in ‘Growth’ plans or ‘Dividend’ (IDCW) plans. With growth plans, investors do not make any money during the time they hold the units – all the profits (or losses) come to them at the time of redemption. With IDCW (formerly dividend) plans, investors could be getting ‘dividend’ payouts, distributed by the AMC at the discretion of the fund manager, during the time they hold the units. 

For example, if we invest Rs 1 lakh in a fund by buying 10,000 units at an NAV of Rs 10, and the fund manager declares a dividend of Rs 1 per unit a few months later, then we would get a dividend of Rs 10,000. We have not redeemed our investment yet, but still, we have money coming into our bank account from the fund. This distribution is taxable.

If there is an IDCW payout during a year, it is subject to a different tax treatment. It goes under the ‘other income’ category in the IT returns.

Taxation by type of mutual fund

Different types of mutual funds are treated differently from a taxation perspective. The government wants to encourage two types of behaviour from investors in the country, and hence provide different – more beneficial – tax treatment for the outcomes (profits) from such behaviours:

  1. Invest in the Indian economy by investing in the Indian equity market
  2. Stay invested for ‘long term’

We will look at what long-term means in the next section. 

Funds with equity allocation of over 65%: To encourage people to invest in the Indian economy by investing in the Indian equity market, the government has a definition for a category of mutual funds and treats investments in them distinctly. They are ‘domestic equity-oriented’ funds. Any fund that invests at least 65% of its portfolio directly in Indian stocks and/or stock-related instruments such as stock derivatives would be considered as a domestic equity oriented fund. Investments in such funds get a slightly better tax treatment than investments in other funds.

ELSS: Apart from this, there is also a super-special category of funds called equity-linked savings scheme (ELSS). Almost every mutual fund company has a scheme that belongs to this category. These schemes are, by definition, equity-oriented schemes. However, investments in these schemes are locked for 3 years, and investors are allowed to take a ‘deduction’ of the money invested in these schemes when they file their returns for the year in which they make this investment. This means that they do not need to pay any taxes on this investment amount. There is a limit to how much one can invest in these schemes, and currently, the limit is Rs 1.5 lakhs. However, please note that the returns from these ELSS schemes are subject to tax just like a normal equity-oriented scheme.

Outside of ELSS and domestic equity-oriented schemes, ALL other mutual fund schemes used to be treated similarly for taxation purposes.

However, changes in tax laws in the 2023 Budget means that these funds can now be split into:

  • Those where equity allocation is between 35% and 65%. This will include the hybrid – multi asset category, some solution-oriented and balanced funds (there are no funds under this now).
  • Other mutual funds that covers all debt mutual funds, gold funds and ETFs, international funds, conservative hybrid funds, fund of funds except those that only invest in equity ETFs and any other fund category with less than 35% exposure to domestic equity.

Long-term vs short-term capital gains

The government would like to encourage you to invest your money, and they would like you to stay invested for the long-term. To encourage this behaviour, mutual fund capital gains (or simply, ‘gains’) is considered either long-term or short-term gain. Long-term gains are subject to less taxes than short-term gains.

Also, what is long-term and what is short-term differs by the type of investment – whether it is made in equity-oriented schemes or something else.

As of now, following are the definitions of long-term and short-term investment tenures:

  1. For domestic equity-oriented investments, gains made by redemption within one year are considered as short-term gains, and those beyond one year are considered as long-term gains.
  2. For funds where the equity allocation is between 35% and 65%, a holding period of less than 3 years will  be considered short-term and over 3 years will be considered long-term.
  3. For everything else, ( debt mutual funds, gold funds and ETFs, international funds, conservative hybrid funds, fund of funds except those that only invest in equity ETFs and any other fund category with less than 35% exposure to domestic equity) the tax treatment will differ based on whether the investment was made before March 31, 2023 or after. For investments made on or before March 31, 2023, gains made by redemption within 3 years are considered as short-term gains, and those beyond three years are considered as long-term gains. For investments made from April 1, 2023 onwards, there will be no difference between long and short term holding. This gain will just be added to total income and taxed at your income tax slab rate

Mutual fund taxation structures

Let’s first look at the taxation structures for capital gains. Please note that apart from the term of investments and the type of mutual funds, tax rates also differ based on whether the taxpayer is an individual or a company. In this write-up, we are dealing only with individual taxpayers.

Tax rate for long-term gainsTax rate for short-term gains
Domestic equity-oriented schemes (over 65% exposure to domestic equity)10% after Rs 1 lakh15%
Funds with equity allocation between 35% and 65%20% after indexationIT slab rate
Investments made on or before March 31, 2023 in other schemes (debt mutual funds, gold funds and ETFs, international funds, conservative hybrid funds, fund of funds except those that only invest in equity ETFs and any other fund category with less than 35% exposure to domestic equity)20% after indexationIT slab rate
Investments made after March 31, 2023 in other schemes (debt mutual funds, gold funds and ETFs, international funds, conservative hybrid funds, fund of funds except those that only invest in equity ETFs and any other fund category with less than 35% exposure to domestic equity)IT slab rate (no indexation)IT slab rate

(Additional stipulations apply for NRI investors – please see the note towards the end of this article)

Here’s a brief explanation of each of those rates:

Domestic equity-oriented schemes:

  1. Tax for long-term gains – This is probably the most beneficial tax rate among all. The first Rs 1 lakh in gains is exempt from tax – you don’t need to pay any tax on them at all. Beyond that, the tax rate is 10%. There is a small, beneficial, exception to this. We will cover this below.
  2. Tax for short-term gains – Simplest to understand. It’s 15%

Funds with equity allocation between 35% and 65% :

  1. Tax for long-term gains – The tax rate here is 20%, but that is after something called ‘indexation’ is applied. We will cover this in the next section. Briefly, indexation is a method by which you can increase your cost (for tax purposes) which in turn reduces your gains.
  2. Tax for short-term gains – All such gains are added to your regular income and taxed at your usual IT slab rate. That is, these gains are not treated as capital gains at all. 

One exception to the above structure is with regards to the long-term gains on domestic equity schemes. Prior to January 2018, this rate was 0% – that is these gains were tax exempt. A 10% rate (beyond Rs 1 lakh) was introduced in the budget then. So, the government decided to make all the gains accrued prior to January 31, 2018 exempt from taxes – you would only need to pay taxes on gains accrued in your investment since that date.

For example, suppose you invested Rs 1 lakh in 2015, and its value is Rs 1.5 lakh as of January 31, 2018. If you redeem the amount later in 2020 at Rs 2.2 lakh value, your total gains would be Rs 1.2 lakh, but you would need to pay taxes only on Rs 70,000 which is the gain accrued after January 31, 2018. 

And, a note about the Rs 1 lakh exemption in this category – this amount applies to the TOTAL gains made from such investments in a year, and it is not on a per-scheme basis. So, if you had gains of Rs 50,000 from 5 different equity oriented schemes in a year, your total gains would Rs 2.5 lakhs, and you would need to pay taxes (of 10%) on Rs 1.5 lakhs (after taking an exemption for Rs 1 lakh)

Other funds

This covers debt mutual funds, gold funds and ETFs, international funds, conservative hybrid funds, fund of funds except those that only invest in equity ETFs and any other fund category with less than 35% exposure to domestic equity.

For investments made on or before March 31, 2023:

  1. Tax for long-term gains – The tax rate will be 20% after indexation is applied.
  2. Tax for short-term gains – Short-term gains will be added to your regular income and taxed at your usual IT slab rate.

For investments made on or after April 1, 2023, there will be no distinction between long and short-term holding and also no benefit of indexation. Gains will simply be added to your income and taxed at your slab rate.

IDCW (Dividend) taxation

Until recently, mutual fund companies would deduct something called dividend distribution tax (DDT) before distributing dividends to investors. And since it was already taxed before it got to the investors, the dividend received by investors was not subject to further taxes.

However, in 2020, the government announced a change to this way of taxation and made it simple. Mutual funds would no longer deduct DDT and dividends would be taxable at the hands of the investor. The only thing the mutual fund company would do is deduct a TDS (tax deducted at source) of 10% if the distributed dividend is higher than Rs 5000.

What happens to the dividend that the investor receives from a taxation perspective? It simply gets added to their income and taxed at their IT slab rate (exactly like short term capital gains for non equity-oriented schemes). And if there was a TDS deducted, it can be claimed back at the time of filing after considering this tax liability.

In general, for most people, this taxation structure could result in a lot of tax outflow, and diminish their post-tax returns. For this reason, IDCW (dividend) schemes of mutual funds are generally avoidable.

Long-term and Short-term – the FIFO principle

Returning, briefly, to the definition of long-term and short-term, we need to take into account a practical issue in this regard. We rarely make one single investment in a mutual fund scheme. We invest first, and after a few months, invest again, and again, and so on. So, there are different dates when we have made our investments. Now, when we redeem from this investment, how do we determine whether our gains or short-term or long-term gains?

The answer to this question is that we need to follow the first-in-first-out principle (FIFO). That is, the units that are redeemed come out in the order that they went in. We always redeem, for accounting and taxation purposes, the earliest units in our investment that are available.

Let’s take an example. Let’s consider the following set of investments into a scheme. Let’s assume that this is a non-equity oriented scheme. Which would mean that for gains to be considered as long-term gains, they would need to be realized after at least 3 years.

DateAmount of investmentNAVNumber of units purchased
January 10, 20151,00,0001010000
February 14, 201650,000124166.666
October 10, 201760,000154000
November 15, 201780,000165000

Now the total number of units we have is 23,166.666. 

Suppose, in June 2018, the NAV of this fund is Rs 18. The total value of our investment would be NAV x number of units = Rs 4,35,000. And we need to withdraw Rs 2,00,000 from this scheme.

Would these be considered short-term gains or long-term gains? Let’s apply the FIFO principle and find out.

First, to redeem Rs 2,00,000 at an NAV of Rs 18, we would need to sell or redeem 11,111 units.

Looking at the table above, we can see that we purchased 10,000 units in January of 2015. That comes out first. Then, we purchased 4166 in February of 2016. We need 1,111 units from that to fully take care of our need for 11,111 units.

So, according to the FIFO principle, we redeemed 10,000 units from our January 2015 investment and 1,111 units from our February 2016 investment.

Now, remember, the date of our redemption is June 2018. Which would mean the 10,000 units redeemed would have completed 3 years and 5 months, and the 1,111 units would have completed 2 years and 4 months.

So, for this redemption, 10,000 units would be considered as long-term units, and 1,111 units would be considered as short-term units. And if we calculate further, we can see that that means Rs 80,000 would be considered as long-term gains, and Rs 6,666 would be considered as short-term gains from your redemption. You would need to pay taxes on these amounts per the respective tax structure.

This math and these calculations may seem daunting. But do not worry. All these are taken care of these days by systems that compute these automatically and present you with the results. It is, however, important that we understand how this works so that we may plan better and understand the implications of our redemption decisions.

SIP investments 

In the example above, we saw a set of random investments made on different dates. However, the most typical case in which multiple investments are made in a single fund happens in the case of systematic investments (SIP). The exact same tax treatment as above applies for SIP investments as well. EACH SIP investment (installment, if you may) are treated as a separate investment with a distinct investment date. When we redeem from a SIP portfolio, the same FIFO principle applies and the gains are categorized as either long-term or short-term based on the time elapsed between each of those dates and the date of redemption.

What is indexation and how it works

Earlier we saw that for some schemes, the applicable tax rate for long-term gains is 20% after indexation. Now, let’s see what this indexation is and how it works.

Earlier, we saw that for equity-oriented investments, there is a beneficial tax treatment provided. Similarly, there is a beneficial tax treatment for some non-equity-oriented mutual fund investments as well. While they apply only for long-term gains from such investments, these can really help investors lower their tax outgo and increase their post-tax returns.

This beneficial treatment is provided in the form of “indexation” of gains. What this essentially means is that a certain amount of gains are exempt from taxes and the taxpayer needs to pay taxes only on the remaining. The amount that is exempt is a percentage that is closely correlated with the inflation rate during the period of that particular investment.

The government publishes, annually, a number called the Cost Inflation Index (CII). The base year for this number was 2001-2002 where it was set at 100. Presently, for the year 2020-21, the value of this index is 301. Following table provides the annual values since the base year:

How indexation lowers tax on long-term gains

We pay capital gains taxes on the capital gains we make on an investment. If we can use a legal mechanism to reduce the capital gains, then we pay lower taxes. Indexation is a legal mechanism that lowers your capital gains.

Indexation lowers your capital gains by “inflating” your cost of purchase – that is, the investment amount. As we know, capital gains are nothing but the difference between the redemption amount and the investment amount. So, if the investment amount becomes higher, then our capital gains become lower.

How can we use indexation to increase our investment cost? By applying the figures from the Cost inflation index table above. Every investment is made in one fiscal year and redeemed in another fiscal year. Since indexation applies only to long term gains, we can assume that at least 3 years have passed since the date of investment at the time of  redemption. The new ‘indexed’ cost of investment can then be calculated using this formula:

Indexed cost of investment = (CII in the year of redemption  / CII in the year of investment) * original cost of investment

Let’s take an example.

Let’s go back to the example from the earlier section where we read about the FIFO principle. An investment was made in January 2015 and a redemption was made in June, 2018 resulting in long-term capital gains of Rs 80,000 (from a non-equity-oriented scheme). That is, investment was made in FY 2014-15 and redemption in FY 2018-19. The original amount of investment for this redemption was Rs 1 lakh.

As we can see from the table above, the CII number for 2014-15 was 240 and that for 2018-19 was 280. So, applying the formula above, we can ‘index’ the cost of investment as follows:

Indexed cost of investment = (280/240) * 1,00,000 = 116,666

Given this new cost of investment, the capital gains goes down from Rs 80,000 to Rs 63,334 (Rs 1.8 lakh – Rs 1.16 lakh), thus lowering the tax burden. To illustrate, instead of having to pay Rs 16,000 as tax (20% tax rate on Rs 80,000), you will need to pay Rs 12,667 (20% tax rate on Rs 63,334).

In future, if you need to know the indexation rate for any year, you can simply google ‘indexation rates’ and get the right number to use in the formula above.

Typically, these calculations are also done by software that compute tax liabilities. So, rarely would one need to do this by hand. However, as always, it’s good to know how this works so we will be able to make right tax-related decisions.

NRI Taxation

There are some differences in mutual fund taxation when it comes to the residential status of the investor. If the investments are made by a non-resident Indian (using a non-resident bank account), these changes apply:

  1. The mutual fund is required to deduct tax at source (TDS) before disbursing a redemption request.
  2. When it comes to dividends, the rate of TDS for amounts beyond Rs 5000 is 20% (not 10%)

One further wrinkle in this is the type of bank account used to make such investments by an NRI. There are two types of NRI bank accounts – repatriable (NRE) and non-repatriable (NRO). Recently, the government has announced that these NRI tax stipulations will NOT apply if the investments were made from a non-repatriable (NRO) account. As of this writing, this is subject to some debate in the tax circles, but it would be a welcome development for NRIs if this came to be true.

How to keep up-to-date on mutual fund taxes

As can be seen throughout this article, we can only talk about taxation as it exists at any given time. These laws, regulations and rates keep changing every budget or even outside of budgets. We need to keep track of such changes to know what is happening with mutual fund taxation rules.

The good news is that mutual fund companies themselves publish nice PDF documents that summarize the various mutual fund taxation rules and rates in a handy format. However, you need to know how to find them 🙂 If you search for mutual fund taxation or mutual fund tax rates, you will only land on articles such as this, and not on these useful at-a-glance documents.

However, if you search using the term ‘mutual fund tax reckoner’ you will find several such documents that you can use for ready reference. Here is one by Tata mutual fund that is very good.

A note on offsetting taxes

Mutual fund investments do not guarantee returns. They also do not guarantee to return the principal amount invested. And that means, you could make losses from your investments. When that happens, the government lets you pay taxes only on the NET gain that you make on your MF investments. This is called ‘offsetting’. However, not all losses on your returns can be offset against all gains. There are rules that govern what can offset what:

  1. You can offset capital losses only against capital gains – not against any other type of income (salary income, for example, or rental income)
  2. Long-term capital losses can be offset against long-term capital gains only
  3. Short-term capital losses can be offset against short-term capital gains or long-term capital gains 
  4. If you are not able to offset your losses sufficiently in a year, you can ‘carry-forward’ the losses for up to 8 financial years to find adequate offsetting gains.

As it usually is when it comes to taxation, it is good to know these principles, but better to leave the finer details to the auditor to get it right when filing the tax returns.

Summary

Paying taxes is important – entire governments depend on us paying our taxes. However, there is nothing wrong with taking advantage of legitimate deductions, exemptions, and concessions provided by the government to reduce our tax outflow and increase our post-tax returns. Understanding how mutual fund taxation works is an important step towards doing so.

Also, understanding taxation helps us make wise decisions with our investments. For example, we can invest in tax-saving schemes to reduce our current year taxes. We can plan our redemption to qualify for beneficial long-term tax rates. We can design our portfolio to have schemes that, overall, will result in a lower tax bill. And many more. For these reasons, it is important to understand and keep up-to-date with the rules and regulations governing the taxation structure for mutual funds. 

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  3. The names of financial products mentioned herein do not in any manner indicate their prospects or returns. The performance in the equity may be adversely affected by the performance of individual companies, changes in the market place and industry specific and macro-economic factors.
  4. The performance of the investments/ products recommended by the RA are subject to a wide range of risks, including but not limited to: performance of the respective companies, changes in equity and debt market conditions, micro and macro factors and forces affecting equity and debt markets, general levels of interest rates and interest rate risk, credit risk, liquidity risk, reinvestment risk, economic slowdown, volatility & illiquidity of the stocks, risks associated with trading volumes, liquidity and settlement systems in equity and debt markets and/or such other circumstance beyond the control of the RA or any of its Associates.
  5. Other risk factors include that may affect the performance of the investments/ products recommended by the RA include but are not limited to economic policies, changes of Government and its policies, acts of God, acts of war, civil disturbance, sovereign action and /or such other acts/ circumstance beyond the control of the RA or any of its Associates.
  6. The recommendations provided by the RA as part of its Research Services may not be suitable to all categories of investors.
  7. The client should read all scheme and security related documents carefully before investing.
  8. Returns and performance figures mentioned in the research report represent past performance and should not be constituted to be future returns or guaranteed returns.

7. Conflict of interest

The RA shall adhere to the applicable regulations/ circulars/directions specified by SEBI from time to time in relation to disclosure and mitigation of any actual or potential conflict of interest. Registration granted by SEBI and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors. Investment in securities market are subject to market risks. Read all the related documents carefully before investing.

General disclosures: PrimeInvestor Financial Research Pvt Ltd (with brand name PrimeInvestor) is an independent research entity offering research services on personal finance products to customers. We are a SEBI registered Research Analyst (Registration: INH200008653). PrimeInvestor Financial Research Pvt. Ltd., its employees, directors or agents, do not have any material adverse disciplinary history as on the date of publication of this report.

Restrictions on trading: To ensure no conflict of interest, the RA declares as follows:

  1. Personal trading activities of the individuals employed as research analysts shall be monitored, recorded and subject to a formal approval by the directors or compliance officer of PrimeInvestor Financial Research Private Limited.
  2. Research analysts employed by PrimeInvestor Financial Research Private Limited or their associates or relatives shall not:
    • Deal/ trade in stocks recommended/ tracked by the research analyst within 30 days before and five days after the publication of a research report;
    • Deal/ trade in securities that the research analyst reviews in a manner contrary to the given recommendation;
    • Purchase or receive securities of the issuer before the issuer's initial public offering, if the issuer is principally engaged in the same types of business as companies that the research analyst follows or recommends.

Disclosures with respect to Research and Recommendations Services:

  1. The RA or its directors or any of its officer/employee does not trade in securities which are subject matter of recommendation.
  2. The RA, or any of its officers, directors, employees, or subsidiaries have not received any compensation/ benefits whether monetary or in kind, from the AMC, company, government, bank or any other product manufacturer or third party, whose products are the subject of its Research Services or investment information.
  3. The Research Analysts who have prepared the research reports that form part of the Research Services (“Research Analyst”) certify that all of the views expressed in the research report accurately reflect their views about the subject company or subject security.
  4. The RA or directors or employees or Research Analyst certify that no part of their compensation was, is, or will be directly or indirectly related to the specific recommendation(s) or view(s) in this report.
  5. The Research Analyst has not served as director, officer or employee in the subject company, AMC or insurance company of the mutual fund or insurance policy that is the subject of this report, or company whose bonds, NCDs, fixed deposits or other savings products that is the subject of this report.
  6. The Research Analyst or their relatives do not have any known direct or indirect material conflict of interest including long/short positions in the subject company.
  7. The Research Analyst may hold investments in the stocks, mutual fund schemes, bonds, fixed deposits, insurance policies, or other products that are the subject of the recommendations provided as part of the Research Services. The Research Analyst certifies that they will not act in a manner contrary to their views on these securities except in the event of significant news or event or change in personal financial circumstances and without formal approval from the directors of PrimeInvestor Financial Research Pvt. Ltd. or the compliance officer.
  8. There are no actual or potential conflicts of interest arising from any connection to or association with any issuer of products/ securities, including any material information or facts that might compromise its objectivity or independence in the carrying on of the Research Services. Such conflict of interest shall be disclosed to the client as and when they arise.
  9. The RA or its directors or its employee or its associates have not managed or co-managed the public offering of any company. The RA or its directors or its employee or its associates have not received any compensation for investment banking or merchant banking of brokerage services from the subject company. The RA or its directors or its employee or its associates have not received any compensation for products or services other than above from the subject company. The RA or its directors or its employee or its associates have not received any compensation or other benefits from the Subject Company or 3rd party in connection with the research report/ recommendation.
  10. The subject company of its research recommendations was not a client of the RA or its directors or its employee or its associates during twelve months preceding the date of recommendation services provided.
  11. The RA or its directors or its employee or its associates has not served as an officer, director or employee of the subject company. Research Analysts has not been engaged in market making activity of the subject company.

PrimeInvestor Financial Research Pvt. Ltd., its Associates, the Research Analysts or their relatives holds ownership of 1% or more, in respect of the said issuer company(ies)? – NO

8. Termination of service and refund of fees:

The RA may terminate or suspend rendering of Research Services to the client in the following circumstances:

  1. On account of suspension/cancellation of registration of RA by SEBI. In case of suspension of certificate of registration of the RA for more than 60 (sixty) days or cancellation of the RA registration, RA shall refund the fees, on a pro rata basis for the period from the effective date of cancellation/ suspension to end of the client’s subscription period.
  2. The RA voluntarily chooses to terminate its Research Service. In the event of such termination of the Research Service, the RA shall refund the fees, on a pro rata basis for the period from the date of such termination of research service to end of the client’s subscription period.

9. Grievance redressal and dispute resolution:

Any grievance related to:

  1. nonreceipt of research report, or
  2. missing pages or inability to download the entire report, or
  3. any other deficiency in the research services provided by RA

shall be escalated promptly by the client to the person/employee designated by RA, in this behalf as under:

Name: Bhavana Acharya
Designation: Director & Compliance Officer, PrimeInvestor Financial Research Pvt Ltd
Email: [email protected]

The RA shall be responsible to resolve grievances within 7 (seven) business working days or such timelines as may be specified by SEBI under the RA Regulations.

RA shall redress grievances of the client in a timely and transparent manner. Any dispute between the RA and his client may be resolved through arbitration or through any other modes or mechanism as specified by SEBI from time to time.

If the client is not satisfied with the response of the RA, he/she can lodge his/her grievances with SEBI at scores.sebi.gov.in. Alternatively, the client may also write to any of the offices of SEBI. For any queries, feedback or assistance, please contact SEBI Office on Toll Free Helpline at 1800 22 7575 / 1800 266 7575

Details on grievances are available on the Website as follows: https://primeinvestor.in/ra-grievance/

10. Additional clauses:

Scope of the Research Service: The Research Services will be limited to providing independent research recommendation and shall not be involved in any advisory or portfolio allocation services. The Research Services are not meant to be tailor-made or customized solutions that specifically apply to each client based on his/her risk profile.

The RA never guarantees the returns on the recommendation provided. Investor shall take note that investment/trading in stocks/Index or other securities is always subject to market risk. Past performance is never a guarantee of same future results. The RA shall not be responsible for any loss to the Investors.

This service is not directed for access or use by anyone in a country, especially the USA, Canada or the European Union countries, where such use or access is unlawful or which may subject PrimeInvestor Financial Research Pvt Ltd or its affiliates to any registration or licensing requirement.

The Research Service, including recommendations, research reports, updates, and other information will be accessible through the RA’s website https://primeinvestor.in only. Such recommendations and updates will not be provided over phone calls.

Fees: Our current fee structure, the term and duration of our subscription for our Research Service, can be viewed on our website: https://primeinvestor.in/prime-pricing. Eligibility for any discounts is ascertained at the time the client subscribes. Any such discount and its tenure shall be at the discretion of the RA.

Subscription and access to content services fall under the purview of Goods and Services Tax (GST) as per the current indirect taxation policy, Government of India. Unless otherwise indicated, prices stated on our website are exclusive of applicable GST, any applicable value added tax (VAT) or other sales taxes. We are a business-to-consumer (B2C) service provider and we do not commit to provide any input tax credit on GST charged on subscription to our Research Service.

We may change the Subscription Fees and charges then in effect, or add new fees or charges which will take effect at the end of the client’s subscription period, by giving notice in advance and an opportunity to cancel renewal of the subscription.

Subscription Access & Renewal: Subscription to the Website commences immediately on the realisation of payment of the Subscription Fees. Subscriptions are set to be renewed automatically at the end of the subscription period.

Unless the client notifies us before the end of his/her subscription period, or the client cancels the auto-renewal mandate within the period specified by law, that the client does not wish to renew his/her subscription, the client’s subscription will renew for the period defined by the client’s subscription plan. We will charge the subscription using the same payment method that you previously used.

Although the client may notify to us his/her intention to his/her subscription, such notice will only take effect at the end of his/her then current subscription period, and he/she will not receive a refund other than as set out under Clause 8 in these Terms.

The client may notify us of his/her wish to cancel his/her subscription by sending an email to [email protected]. The client must provide at least 5 business days advance notice for this to be implemented.

Refunds: There can be no cancellation and refund of subscription fee paid once the subscription is active, other than as stated in Clause 8 of these Terms. If the client is entitled to a refund as specified under Clause 8 of these Terms, the RA will credit that refund to the card or other payment method used by the client to submit payment, unless it has expired - in which case the RA will contact the client to proceed with the refund. If we do issue a refund or credit due to circumstances outside the obligations specified under Clause 8, we are under no obligation to issue the same or a similar refund in the future.

General disclaimers: The recommendations made herein in the Research Services are expression of views and/or opinions and should not be deemed or construed to be advice for the purpose of purchase or sale of any security, nor a solicitation or offering on any investment/ trading opportunity on behalf of the company, AMC, insurance company, or issuer of security referred to herein.

The content and research reports generated by the RA does not constitute or is not intended to constitute an offer to buy or sell, or a solicitation to an offer to buy or sell financial products, units or securities.

The information/ opinion/ views mentioned in research reports or by the RA are not meant to serve as a professional guide to the client or recipients of this Report. The research report, recommendation, or any other content published by the RA do not assure or guarantee any minimum or fixed returns to the client or recipients of the reports/ recommendations/ content.

Use of this information is at the client’s own risk. The client must make his/ her own investment decisions based on his/her specific investment objective and financial position and using such independent advisors as he/she believes necessary. The services rendered by the RA are on a best-effort basis. All information in the content or research report of the RA is provided on an as is basis. Information is believed to be reliable but the RA does not warrant its completeness or accuracy and expressly disclaim all warranties and conditions of any kind, whether express or implied.

While due care has been taken to ensure that the disclosures, information, and opinions given are fair and reasonable, PrimeInvestor Financial Research Pvt Ltd and/or none of its officers, directors, partners, employees, agents, subsidiaries, affiliates or business associates shall be liable for any direct, indirect, special, incidental, consequential, punitive or exemplary damages, including lost profits arising in any way whatsoever from the information/ opinions/ views contained in the research report and recommendations that form part of the Research Service, and/or mails, social media or notifications issued by PrimeInvestor Financial Research Pvt Ltd or any other agency appointed/authorised by PrimeInvestor Financial Research Pvt Ltd. Returns and performance figures mentioned in the research report represent past performance and should not be constituted to be future returns or guaranteed returns.

Any agreements, transactions or other arrangements made between the client and any third party named on (or linked to from) the Website are at your own responsibility and entered into at your own risk. Any information that you receive via the Website, whether or not it is classified as “real time”, may have stopped being current by the time it reaches you. Market price information may be rounded up/down and therefore may not be entirely accurate.

The purpose of these disclosures is to provide essential information about the Research Services in a manner to assist and enable the prospective client/client in making an informed decision for engaging in Research Services before onboarding.

History, present business and background: PrimeInvestor Financial Research Private Limited is registered with SEBI as Research Analyst with registration no. INH200008653. The Research Analyst got its registration on August 19, 2021 and is engaged in offering research and recommendation services.

Disciplinary history: There are no pending material litigations or legal proceedings against the Research Analyst. As on date, no penalties / directions have been issued by SEBI under the SEBI Act or Regulations made thereunder against the Research Analyst relating to Research Analyst services.

Details of the RA's associates: No associates.

Usage of Website Content: This Website is controlled and operated by the RA. All material, including research reports, recommendations, portfolios, ratings, lists of financial products, illustrations, statements, opinions, views, photographs, products, images, artwork, designs, text, graphics, logos, button icons, images, audio and video clips and software (collectively, “Content”) are protected by copyrights, trademarks and other intellectual property rights that are owned and controlled by the RA or by other parties that have licensed their material to us.

Except where otherwise agreed in writing with the RA, material on the Website is solely for the client’s personal, non-commercial use. Except as provided below, the client must not copy, reproduce, republish, upload, post, transmit or distribute such material in any way, including by e-mail or other electronic means and whether directly or indirectly and the client must not assist any other person to do so.

Without the prior written consent of the RA, modification of the materials, use of the materials on any other web site or networked computer environment or use of the materials for any purpose other than personal, non-commercial use is a violation of the copyrights, trademarks and other proprietary rights, and is prohibited. Any use for which the client receives any remuneration, whether in money or otherwise, is a commercial use for the purposes of these Terms.

The client may occasionally distribute a copy of a research report, or a portion of the same, from the Website in non-electronic form to a few individuals without charge, provided the client includes all copyright and other proprietary rights notices in the same form in which the notices appear, original source attribution, and the phrase “Used with permission from PrimeInvestor Financial Research Pvt. Ltd.”

While the client may occasionally download and store research reports or information from the Website for his/her personal use, he/she may not otherwise provide others with access to the same. The foregoing does not apply to any sharing functionality we provide through the Website that expressly allows the client to share Content or links to Content with others. In addition, the client may not use Content he/she has downloaded for personal use to develop or operate an automated trading system or for data or text mining.

The client agrees not to rearrange or modify the Content available through the Website. The client agrees not to display, post, frame, or scrape the Content for use on another website, app, blog, product or service, except as otherwise expressly permitted by these Terms. You agree not to create any derivative work based on or containing the research products and Content. The framing or scraping of or in-line linking to the Services or any Content contained thereon and/or the use of webcrawler, spidering or other automated means to access, copy, index, process and/or store any Content made available on or through the Services other than as expressly authorized by us is prohibited.

The client further agrees to abide by exclusionary protocols (e.g., Robots.txt, Automated Content Access Protocol (ACAP), etc.) that may be used in connection with the Research Services. The client may not access parts of the Research Services to which he/she is not authorized, or attempt to circumvent any restrictions imposed on your use or access of the Services.

As a general rule, the client may not use the Content, including without limitation, any Content made available through one of our RSS Feeds, in any commercial product or service, without our express written consent.

The client may not create apps, extensions, or other products and services that use our Content without our permission. The client may not aggregate or otherwise use our Content in a manner that could reasonably serve as a substitute for a subscription to the Website.

The client may not access or view the Services with the use of any scripts, extensions, or programs that alter the way the Services are displayed, rendered, or transmitted to you without our written consent.

The client agrees not to use the Services for any unlawful purpose. We reserve the right to terminate or restrict the client's access to the Website if, in our opinion, the client's use of the Services may violate any laws, regulations or rulings, infringe upon another person's rights or violate these Terms.

Prohibited content: The Website includes comments sections, blogs and other interactive features that allow interaction among clients and between clients and the RA. We call the information posted by or contributed by users “Contributed Content.” In the course of availing of the Research Services or uploading any post or comment on the Website, the client shall not post any Contributed Content that (i) contains nude, semi-nude, sexually suggestive photos, (ii) tends or is likely to abuse, harass, threaten, impersonate or intimidate other users of the Website and/or Research Services, (iii) is lascivious or appeals to the prurient interest or if its effect is such as to tend to deprave and corrupt persons who are likely to use or have access to the Website and/or Services, or (iv) otherwise violates, is prohibited or restricted by applicable law, rule or regulation, is offensive or illegal or violates the rights of, harms or threatens the safety of other users of the Website and/or Services (collectively “Prohibited Content”).

We reserve the right to cease to provide the client with the Research Services or access to the Website, or terminate your subscription, with immediate effect and without notice and liability, for violating these Terms, applicable law, rules or regulations and reserves the right to remove Prohibited Content which is in violation of these Terms, or is otherwise abusive, illegal or disruptive. The determination of whether any content constitutes Prohibited Content, violates these Terms, or is otherwise abusive illegal or disruptive, is subject to the sole determination of the Firm.

Changes to Research Services: We are constantly endeavouring to improve the quality of Research Services provided to our clients. Due to this, the form and nature of the Research Services provided may change from time to time without any prior notice to the client. We reserve the right to introduce and initiate new features, functionalities, components to the Website and/or Research Services and/or change, alter, modify, or discontinue existing ones without any prior notice to the client.

Warranty and liability disclaimer: The Website, Research Services, and all the materials and services, included on or otherwise made available to the client through this Website is provided by the RA on an “as is” and “as available” basis without any representation or warranties, express or implied except otherwise specified in writing. Without prejudice to the foregoing paragraph, the RA does not warrant that:

  • This Website and/or Research Services will be constantly available, or available at all;
  • The information on this Website or provided through the Research Services is complete, true, accurate or not misleading; or
  • The quality of any products, services, information, or other material that you obtain through the Website or Services will meet your expectations.

The RA, to the fullest extent permitted by law, disclaims all warranties, whether express or implied, including the warranty of merchantability, fitness for particular purpose and non-infringement. The RA makes no warranties about the accuracy, reliability, completeness, or timeliness of the Website, Research Services, Content, Contributed Content, Services, software, text, graphics and links.

The RA does not warrant that this Website, Research Services, information, content, materials, or any other material included on or otherwise made available to you through this Website, their servers, or electronic communication sent by the RA are free of viruses or other harmful components.

Nothing on this Website constitutes, or is meant to constitute, advice of any kind.

Indemnification: The client:

  1. Represents, warrants and covenants that no materials of any kind provided by him/her will:
    1. Violate, plagiarise, or infringe upon the rights of any third party, including copyright, trademark, privacy or other personal or proprietary rights; or
    2. Contain libellous, Prohibited Content or other unlawful material;
  2. Hereby agree to indemnify, defend and hold harmless the RA and all of the RA’s officers, directors, owners, agents, customers/clients, information providers, affiliates, licensors and licensees (collectively, the “Indemnified Parties”) from and against any and all liability and costs, including, without limitation, reasonable advocate’s fees, incurred by the Indemnified Parties in connection with any claim arising out of any breach by the client of these Terms or the foregoing representations, warranties and covenants. The client shall cooperate as fully as reasonably required in the defence of any such claim. The RA reserves the right, at its own expense, to assume the exclusive defence and control of any matter subject to indemnification by the client.

Applicable law: This Website, including the Content and Contributed Content and information contained herein, and the provision of Research Services shall be governed by the Securities and Exchange Board of India, laws of the Republic of India and the courts of Chennai, India which shall retain exclusive jurisdiction to entertain any proceedings in relation to any disputes arising out of the same. As such, the laws of India shall govern any transaction completed using this Website.

Information gathered and tracked: Information submitted or collected on the Website or pursuant to the use of the Services is stored in a database. Specifically, we store the username, name, e-mail address, contact number, as submitted or collected on our Website or through the provision of the Research Services. We may use such information to send out occasional promotional materials, including alerts on new Services available, or other promotional and marketing material relating to our clients and customers.

In accordance with the Information Technology Act 2000, the name and the details of the Grievance Officer at PrimeInvestor is provided below:

Mr. Srikanth Meenakshi
PrimeInvestor Financial Research Pvt. Ltd., Registered office: 659, 4th Avenue, D-Sector, Anna Nagar Western Extension, Chennai 600 101.
Email: [email protected]

11. Mandatory notice:

Clients shall be requested to go through Do’s and Don’ts while dealing with RA as specified in SEBI master circular no. SEBI/HO/MIRSD-POD-1/P/CIR/2024/49 dated May 21, 2024 or as may be specified by SEBI from time to time.

12. Optional Centralised Fee Collection Mechanism:

SEBI has operationalized a centralized fee collection mechanism for IA and RA. Under this mechanism, clients shall pay fees to IAs/RAs through a designated platform/portal administered by a recognized Administration and Supervision body. This is an optional mechanism for the registered entities. At this time, PrimeInvestor has opted out of this fee collection mechanism. Therefore, all subscription payments for the Research Services will be through the modes as specified in Clause 5 of these Terms.

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