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Microlesson · 5-min read

Market Linked Debentures, Specified Mutual Funds & Unlisted Bonds [Section 50AA]

## Capital Gain on MLDs, Specified Mutual Funds & Unlisted Bonds/Debentures [Section 50AA]

Section 50AA creates a special regime for three categories of debt-oriented instruments. The gain is always Short-Term irrespective of period of holding.

### Key Definitions

  • Market Linked Debenture (MLD): A security whose principal component is in the form of a debt security but whose returns are linked to market returns on other underlying securities (often equity indices). Despite the equity-linked returns, principal is debt.
  • Specified Mutual Fund: A mutual fund in which more than 65% of its total proceeds is invested in debt instruments (i.e., debt-oriented funds).

### Tax Treatment

Capital gain on transfer/redemption of the following is deemed to be Short-Term Capital Gain (STCG) regardless of holding period:

1. Market Linked Debentures

2. Specified Mutual Fund units acquired on or after 1.4.2023

3. Unlisted Bonds or Debentures

### Why this special regime?

These instruments were earlier used for arbitrage — investors got equity-like returns with debt-fund / LTCG treatment (paying just 10% / 20% with indexation). To plug this loophole, Section 50AA mandates STCG taxation at slab rate, removing both indexation and concessional LTCG rates.

### Practical Impact

  • No indexation benefit available
  • No Section 54-series exemptions applicable (those generally need LTCG)
  • Taxed at slab rate of the assessee — could be as high as 30% + surcharge

Worked example

### Example 1

Example: Mr. E purchased units of a debt-oriented mutual fund (Specified MF) on 1.5.2023 for ₹10 lakh. Sells on 1.7.2026 for ₹13 lakh.

Despite holding > 36 months, since the units were acquired after 1.4.2023, the gain is STCG = ₹3 lakh taxable at slab rate. No indexation, no LTCG concession.

⚠️ Common exam mistakes

  • Applying LTCG rates / indexation to MLDs and Specified MFs.
  • Forgetting that the 1.4.2023 cut-off applies to Specified MFs only — units acquired before that date may still be eligible for LTCG.
  • Treating listed bonds the same as unlisted bonds — only unlisted bonds/debentures fall under 50AA's automatic STCG rule.
Bare-Act text Section 50AA · Income-tax Act, 1961 · click to expand
Notwithstanding anything contained in clause (42A) of section 2 or section 48, the full value of consideration received or accruing as a result of the transfer or redemption or maturity of a Specified Mutual Fund acquired on or after the 1st day of April, 2023, a Market Linked Debenture, or an unlisted bond or an unlisted debenture which is transferred or redeemed or matured on or after the 23rd day of July, 2024, as reduced by— (i) the cost of acquisition of the debenture or unit; and (ii) the expenditure incurred wholly and exclusively in connection with such transfer or redemption or maturity, shall be deemed to be the capital gains arising from the transfer of a short-term capital asset.
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