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Microlesson · 5-min read

Equity Oriented Fund & Zero Coupon Bond — Meaning

## Equity Oriented Fund (EOF)

An Equity Oriented Fund is a mutual fund scheme or an insurance company scheme (ULIP) that satisfies a minimum equity-investment threshold. The threshold depends on whether the fund invests directly in shares or indirectly through another fund:

SituationRequired investment in equity
Fund-of-fund (invests in another fund)90% of total proceeds in listed units of another fund, AND that other fund invests ≥ 90% of its total proceeds in listed equity shares of domestic companies
Other (direct) cases65% of total proceeds in listed equity shares of domestic companies

How the percentage is measured: The percentage of equity shareholding or units held is computed as the annual average of the monthly averages of the opening and closing figures (not a single snapshot on one date).

Why it matters: classification as an EOF determines whether the concessional capital gains regime under sections 111A / 112A applies.

## Zero Coupon Bond [Section 2(48)]

A Zero Coupon Bond is a bond that meets all of the following:

1. Issued by an eligible entity — infrastructure capital company / fund, infrastructure debt fund, public sector company, or a scheduled bank.

2. No payment or benefit is received or receivable before maturity or redemption from the issuing entity (i.e. there is no periodic coupon — the return comes only from the discount).

3. It is notified by the Central Government.

Tax treatment: Income on the transfer of a zero coupon bond — provided it is not held as stock-in-trade — is taxed as capital gains. Importantly, "transfer" here includes maturity or redemption, so gains crystallise even when the bond is simply redeemed at maturity.

⚠️ Common exam mistakes

  • Taking a single date's equity percentage instead of the annual average of monthly averages of opening and closing figures.
  • Using the 65% threshold for a fund-of-fund — the fund-of-fund route requires 90% in listed units of another fund AND that fund holding 90% in listed domestic equity.
  • Forgetting that redemption/maturity of a zero coupon bond is itself a 'transfer' and therefore a taxable capital gains event.
  • Treating zero coupon bond income held as stock-in-trade as capital gains — that is business income.
Bare-Act text Section 2(48) · Income-tax Act, 1961 · click to expand
Section 2(48): 'Zero coupon bond' means a bond issued by any infrastructure capital company or infrastructure capital fund or infrastructure debt fund or public sector company or scheduled bank on or after the 1st day of June, 2005, in respect of which no payment and benefit is received or receivable before maturity or redemption from such issuing entity and which the Central Government may, by notification in the Official Gazette, specify in this behalf.
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