Form 64C is the annual per-investor income statement that a SEBI-registered Category I or Category II Alternative Investment Fund issues to each of its unit-holders. It is central to the tax pass-through mechanism that gives Cat I / Cat II AIFs their favourable tax character, and is a core deliverable of the fund administrator.
Scope note: Form 64C applies specifically to Category I and Category II AIFs (tax pass-through). Category III AIFs are taxed at fund level under Section 115UB / relevant sections and issue Form 64D-style reporting instead. Always confirm the current-year rules with your tax counsel.
What Form 64C contains
Form 64C reports the character-by-character income attributable to each investor for the financial year. Typical line items include:
Interest income
Dividend income
Short-term capital gains (STCG)
Long-term capital gains (LTCG) — split by asset class where relevant
Business income (limited scenarios)
Other income — with disclosure of sources
Total income attributable to the investor for the year
Each amount is computed at the investor's proportionate share of the fund's income, adjusting for the timing of the investor's subscription and any distributions.
Who files it, when
The fund — via its manager and fund administrator — files a consolidated Form 64C-style return with the Income Tax Department and simultaneously issues the per-investor Form 64C to each unit-holder. The deadline is typically on or before 30 November following the end of the relevant financial year, though investors expect to receive their copy earlier so they can complete their own returns.
How a fund administrator produces Form 64C
Preparing Form 64C is a downstream activity that depends entirely on the quality of the fund accounting done through the year. A capable AIF fund accounting software should:
Classify every income event by tax character at booking time (dividend vs interest vs capital gain).
Track the LP-wise attribution schedule — including partial-year holdings, transfers and side-pocket units.
Reconcile total 64C income back to the audited financial statements.
Produce a signed per-investor Form 64C PDF and a machine-readable export for e-filing.
AIFLedger generates Form 64C at the click of a button once the year-end journal is closed, and dispatches signed statements through the AIF investor servicing software LP portal so investors download them directly.
Common pitfalls
Character contamination — a single "misc income" GL line that should have been split into three tax characters. Fix upstream by enforcing income-classification at journal entry.
Missing partial-year adjustments — investors who came in mid-year get over-allocated income. Fix with a time-weighted attribution model.
Late issuance — LPs need their 64C to complete their tax returns; late issuance damages relationships. Fix with automated dispatch on the LP portal.