CBDT Notifies “Ten Year Zero Coupon Bond of REC Ltd.” as Zero Coupon Bond

By Aaerm Law Associates | June 3, 2025


🧭 Introduction

In a crucial move to promote long-term infrastructure investment, the Central Board of Direct Taxes (CBDT) issued Notification No. 52/2025 on May 30, 2025. Through this, the government has officially recognized the “Ten Year Zero Coupon Bond of REC Ltd.” as a zero coupon bond under Section 2(48) of the Income-tax Act, 1961.

This announcement highlights India’s push toward leveraging tax-efficient, structured financial instruments to finance critical infrastructure projects. Consequently, the bond’s classification ensures tax benefits for investors while helping REC Ltd. raise significant capital without periodic interest payments.


📌 Key Highlights of the Bond

The CBDT notification outlines specific terms and features that define this zero coupon bond:

ParticularsDetails
IssuerREC Ltd. (Rural Electrification Corp)
Bond NameTen Year Zero Coupon Bond of REC Ltd.
Bond Life10 years and 6 months
Issue DeadlineOn or before March 31, 2027
Maturity Value₹5,000 crores
Discount at Issue₹2,200 crores
Number of Bonds5,00,000 units

Unlike traditional bonds, zero coupon bonds do not pay periodic interest. Instead, they are issued at a discount and redeemed at face value, offering returns upon maturity.


💰 Tax Implications for Investors

From a tax standpoint, these bonds offer substantial advantages:

  • Capital Gains Classification: The Income-tax Act treats gains on redemption as long-term capital gains.
  • Tax Rate: Investors benefit from a lower tax rate of 12.5% per annum.
  • No TDS: Typically, zero coupon bonds do not attract Tax Deducted at Source (TDS) on periodic payouts—because there aren’t any.
  • Ideal for HNIs and Institutions: Given the maturity horizon and tax efficiency, these bonds suit long-term investors like mutual funds, insurance companies, and high-net-worth individuals.

Thus, these bonds not only preserve capital but also reduce the tax burden compared to regular interest-bearing securities.


📈 Market Reception and Previous Success

The market has historically responded well to REC’s financial instruments. For instance, in September 2024, REC issued a similar zero coupon bond, which was oversubscribed 7 times against its base size of ₹5,000 crore.

This demand indicates:

  • Strong trust in REC Ltd.’s creditworthiness
  • High appetite for tax-optimized fixed income products
  • Increased confidence in India’s infrastructure growth story

Given this background, financial analysts expect the upcoming bond issue to receive an equally enthusiastic response from institutional and retail investors alike.


📃 Listing and Liquidity

In line with regulatory best practices and investor expectations, these bonds are slated for listing on both:

  • National Stock Exchange (NSE)
  • Bombay Stock Exchange (BSE)

This listing enhances liquidity, ensuring that investors can trade the bonds in the secondary market. Furthermore, it supports the government’s vision to broaden capital market participation and increase transparency in bond offerings.


🧾 Legal & Regulatory Framework

The CBDT notification derives authority from:

  • Clause (48) of Section 2 of the Income-tax Act, 1961
  • Rule 8B (sub-rules 3 & 6) of the Income-tax Rules, 1962

This regulatory backing provides clarity to issuers and investors while ensuring that the tax benefits associated with these instruments are well-anchored in law.

Moreover, the alignment of these rules with India’s fiscal and infrastructure policy goals demonstrates the government’s holistic approach to nation-building through structured finance.


🌐 Conclusion

The official recognition of the Ten Year Zero Coupon Bond of REC Ltd. as a zero coupon bond represents a strategic milestone. It combines the benefits of long-term capital formation, tax efficiency, and capital market development.

Investors gain a reliable fixed-income option with significant tax advantages, while REC Ltd. receives the necessary capital for power and rural electrification projects. As the issuance date approaches, market participants eagerly await subscription details and listing timelines.

This initiative is not just a step forward for bond markets but also a testament to India’s evolving financial ecosystem.