Harun Raaj & AssociatesHarun Raaj & Associates
AIF & Fund Management Services

AIF Fund Services

AIF Fund Services

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Regulatory Framework

Our AIF fund services support sponsors and fund managers across the three categories of Alternative Investment Funds recognised under Regulation 3(4) of the SEBI (Alternative Investment Funds) Regulations, 2012 — Category I (venture capital, SME, social venture, infrastructure, and angel funds), Category II (private equity and debt funds not employing leverage beyond operational needs), and Category III (funds using complex or leveraged trading strategies, including hedge funds).

Because the category a fund is classified under determines both its regulatory obligations and its tax treatment, correct category selection at the structuring stage is critical. Category I and Category II AIFs benefit from a pass-through tax regime under Section 115UB of the Income-tax Act, 1961 (carried forward into the Income-tax Act, 2025 under Sections 196–197 and Schedule XXI), meaning income is taxed in investors' hands rather than at the fund level, subject to exemptions under Sections 10(23FBA)/(23FBB). Category III AIFs, by contrast, are taxed at the fund level as an Association of Persons, at slab rate or maximum marginal rate — a distinction that materially affects investor returns and should be factored into fund structuring decisions from the outset.

Our fund services span category classification and structuring advice, coordination with the fund's registered SEBI intermediary on category-specific compliance obligations, and ongoing advisory support as a fund's strategy evolves within its chosen category's regulatory boundaries.

Overview

AIF Fund Services is the end-to-end operating layer for alternative investment funds: from the moment the sponsor decides to launch a fund to the day-to-day accounting, reporting and compliance that keeps it registered and credible with investors. It sits on the SEBI (Alternative Investment Funds) Regulations 2012, which govern how the fund is registered, how it raises capital, how it reports and how it is audited.

The sponsor's job is investment. The fund's legal existence — the constitutive documents, the placement memorandum, the investor agreements, the subscription and redemption mechanics — is a parallel project that decides whether investors sign. So is the accounting layer: fund accounting is not company accounting, with NAV computation, carried interest and fee waterfalls that lenders, investors and SEBI all scrutinise.

A fund that shortcuts this operating layer pays for it in investor trust and regulatory friction. Subscription monies collected without the right documentation, NAVs that cannot be reconciled, quarterly reports filed late — each one is visible to SEBI under the AIF Regulations and to investors in their fund reports. In a market where fund managers compete on governance, the operating layer is the product.

This service is for fund sponsors, investment managers and family offices running or launching AIFs. We provide the chartered-accountant backbone — fund setup documentation, investor onboarding and certification, accounting and NAV support, audit coordination, and the full SEBI reporting calendar — so the investment manager can focus on returns while the vehicle stays compliant.

How It Works

  1. 1

    Fund Operating Blueprint

    We design the fund's operating model — legal vehicle, service providers, fee structure and reporting calendar under the AIF Regulations 2012.

    Harun Raaj & Associates does this1-2 weeks
  2. 2

    Fund Documentation

    We prepare the constitutive documents, placement memorandum and investor documentation.

    Harun Raaj & Associates does this2-4 weeks
  3. 3

    Investor Onboarding & Certification

    We run investor eligibility checks, accredited investor certification and subscription documentation.

    Harun Raaj & Associates does thisAs investors commit
  4. 4

    Accounting & NAV Support

    We maintain fund books, support NAV computation and reconcile portfolio transactions.

    Harun Raaj & Associates does thisMonthly
  5. 5

    Audit & SEBI Reporting

    We coordinate the annual audit and file quarterly and annual reports with SEBI under the Regulations.

    Harun Raaj & Associates does thisOngoing

Frequently Asked Questions

What SEBI regulations govern an AIF and how are the categories defined?
AIFs are registered under the SEBI (Alternative Investment Funds) Regulations 2012. Category I covers VCFs, SME funds, social-impact funds, and infrastructure funds; Category II covers PE and debt funds; Category III covers hedge funds and entities using leverage. Each category carries distinct investment restrictions and reporting obligations set out in Schedules I to III of the Regulations. Registration is mandatory under Regulation 3 before accepting commitments from investors.
What periodic filings must a registered AIF submit to SEBI?
Regulation 22 requires every AIF to file quarterly reports with SEBI in the prescribed format through the SEBI EFS portal within 10 days of each quarter end. An annual audited statement under Regulation 20(13) — including NAV per unit, management fee disclosures, and a portfolio schedule at fair value per SEBI circular SEBI/HO/AFD/PoD-1/P/CIR/2023/131 — must be submitted within 180 days of the fiscal year end.
How is income from an AIF taxed in the hands of investors?
Category I and II AIFs enjoy pass-through status under Section 115UB of ITA 1961 — income retains its character (capital gains, interest, dividend) and is taxed in the hands of investors at applicable rates; the fund files Form 64B to report allocations to each investor. Category III AIFs are taxed at fund level: business income at 42.74% (surcharge and cess), STCG under Section 111A at 15%, and LTCG under Section 112A at 10% above Rs 1 lakh.
Does GST apply to the investment manager and are there RCM obligations?
The investment manager charges a management fee that is a taxable supply of portfolio management services under SAC 997152, attracting 18% GST under the CGST Act 2017. Where the fund pays sub-advisors or placement agents outside India, Reverse Charge Mechanism applies under Sections 9(3) and 5(3) of the CGST Act and IGST Act 2017 respectively — the fund must obtain GST registration and discharge RCM on such import-of-services payments.
What are the key annual compliance obligations for AIF accounting and audit?
Regulation 20(13) of the SEBI AIF Regulations mandates annual audit by a Chartered Accountant with a valid CoP. The accounts must disclose NAV per unit, performance-linked management fees, carried interest accruals computed per the fund LPA, and a schedule of investments at fair value. In addition, Form 64A (fund-level) and Form 64B (investor-level) must be filed under Section 115UB read with Rule 12CB of the Income Tax Rules 1962 before the due date under Section 139(1) of ITA 1961 (or Section 263 of ITA 2025 for TY 2026-27 onwards).

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