AIF Tax Forms Explained: Form 64C, Form 64D, Form 78, Form 79 and ITR Reporting

Investing in an Alternative Investment Fund (AIF) can provide access to private equity, venture capital, private credit, real assets and other investment opportunities beyond traditional mutual funds and listed securities. But for investors, understanding the tax paperwork can be almost as important as understanding the investment itself.

The terminology becomes particularly confusing because India's tax framework transitioned from the Income-tax Act, 1961 to the Income-tax Act, 2025 from 1 April 2026. Consequently, investors may encounter references to Form 64C, Form 64D, Form 78 and Form 79, depending on the tax year being discussed.

This guide explains the AIF tax forms framework from an investor's perspective, including what each form means, who prepares it, how pass-through income works, how to reconcile the statement with Form 26AS and AIS, and how to report AIF income in an income-tax return.

Old vs New AIF Tax Forms

The Income Tax Department expressly maps Form 64C to Form 78 and Form 64D to Form 79 under the new rules. 

Which Tax Forms Apply to AIF Investors?

The first thing an investor should establish is which tax year the income relates to.

The old Income-tax Act, 1961 continues to govern tax years beginning before 1 April 2026. Therefore, income relating to FY 2025-26 / AY 2026-27 falls under the earlier framework, while the new Income-tax Act, 2025 applies to the tax year beginning 1 April 2026, commonly referred to as Tax Year 2026-27. 

This distinction is critical when dealing with AIF tax forms.

Under the earlier framework:

• Form 64C was the investor-level statement.
• Form 64D was the statement furnished to the tax authorities by the investment fund.

Under the new framework:

• Form 78 is the individual unit-holder statement.
• Form 79 is the consolidated statement filed by the investment fund.

The underlying pass-through concept remains substantially similar: eligible investment-fund income is generally attributed to unit holders according to the statutory framework, retaining its nature and proportion, subject to the rules governing losses. 

What Was Form 64C Under the Earlier Tax Framework?

Form 64C meaning

Form 64C meaning can be understood simply as the income statement provided by an eligible investment fund to its unit holder.

Under Section 115UB and Rule 12CB of the earlier framework, Form 64C contained details of income or eligible loss attributed to an investor from the investment fund.

Searches for Form 64C AIF or AIF Form 64C generally refer to this investor-level statement.

It could include information relating to:

• Business or professional income
• Long-term capital gains
• Short-term capital gains
• Dividend income
• Other-source income
• Relevant tax classifications
• Applicable TDS information
• Certain eligible loss details
• Date of payment or credit

The investor used this information while preparing the tax return and reporting pass-through income.

Under the earlier Rule 12CB framework, Form 64C was to be furnished to the unit holder by 30 June of the following financial year. 

So, an AIF tax statement received from a fund was not simply a distribution receipt. It was an important tax-reporting document that helped the investor determine the nature and amount of income to be reported.

What Was Form 64D Under the Earlier Tax Framework?

Form 64D meaning

Form 64D meaning is different from Form 64C.

Form 64D was the consolidated statement filed by the investment fund with the Income Tax Department, containing information regarding income paid or credited to its unit holders.

In simple terms:

Form 64D = fund-level reporting

Form 64C = investor-level reporting

The fund was responsible for preparing and furnishing the relevant information, while the investor received Form 64C.

Under the amended Rule 12CB applicable to the later years of the old regime, Form 64D was required to be furnished electronically by 15 June of the following financial year and Form 64C by 30 June. 

Therefore, when someone searches for Form 64D AIF or AIF Form 64D, they are generally referring to the fund's consolidated statutory reporting rather than a form that the individual investor files independently.

What Is Form 78 Under the Income-tax Rules, 2026?

The new rules introduce Form 78 as the successor to Form 64C.

Form 78 meaning

Form 78 meaning: it is the statement of income distributed by an investment fund and provided to each unit holder under Section 224 of the Income-tax Act, 2025 and Rule 145 of the Income-tax Rules, 2026.

The Income Tax Department specifically identifies Form 78 as the new-form equivalent of Form 64C.

Therefore:

Form 64C → Form 78

If you see the phrase Form 78 investment fund, it refers to this investor-specific statement.

Is Form 78 filed separately by the investor?

No.

This is one of the most important points about the new AIF tax forms.

Form 78 is a child form generated from Form 79. The investment fund first files Form 79. The system then generates individual Form 78 statements for the unit holders. The fund downloads and furnishes the relevant Form 78 to each investor.

The statutory timeline is:

• Form 79: 15 June of the following financial year
• Form 78: 30 June of the following financial year

What Is Form 79 Under the Income-tax Rules, 2026?

Form 79 meaning

Form 79 meaning: it is the consolidated statement of income paid or credited by an investment fund to persons liable to tax on that income.

It is the new counterpart of Form 64D.

Therefore:

Form 64D → Form 79

A Form 79 investment fund filing is made by the investment fund rather than by the individual investor.

The Income Tax Department's guidance states that eligible Category I and Category II AIFs having pass-through taxation status are required to file Form 79.

The form captures information such as:

• Fund name and PAN
• Registered office details
• Legal status
• Directors/trustees/partners
• SEBI/IFSCA registration details
• Total income
• Head-wise income
• Losses and set-offs
• Income proportions
• Unit-holder-wise distributions
• Relevant loss information
• Payment/credit details

It must be electronically furnished by the prescribed person responsible for making or crediting income on behalf of the fund.

When Do Legacy Forms 64C and 64D Remain Relevant?

The transition to the Income-tax Act, 2025 does not mean that Forms 64C and 64D suddenly become irrelevant for every tax year.

The Income Tax Department has clarified that tax years beginning before 1 April 2026 continue to be governed by the earlier framework. For example, AY 2026-27, relating to FY 2025-26, is governed by the old Act even though the return may be filed after 1 April 2026. 

Consequently:

• Income relating to the earlier framework → Forms 64C/64D
• Income relating to the new tax year → Forms 78/79

This is why investors should not automatically replace every old document with a new form number.

The practical rule for AIF tax forms is:

Identify the tax year first. Then identify the law and prescribed form applicable to that tax year.

Form 64C vs Form 78: What Has Changed for Investors?

Form 64C vs Form 78

The most straightforward comparison is:

The core purpose has therefore not been fundamentally reinvented. The major change is the statutory framework, form numbering and certain reporting fields.

One notable improvement is the addition of the date of payment or credit field to Form 79, which enables the system-generated Form 78 to populate that information more consistently.

Form 64D vs Form 79: What Has Changed for Investment Funds?

Form 64D vs Form 79

The new AIF tax forms framework also standardises capital-gain classification and introduces a payment/credit-date field at the parent-form level. The Income Tax Department says this is intended to make the generation of investor statements and subsequent ITR reporting more consistent. 

Who Prepares, Files and Provides Each AIF Tax Form?

The responsibility can be understood through this simple flow:

Investment Fund → Form 79 → Income Tax Department

Investment Fund → Form 78 → Unit Holder

The fund or the person responsible for making or crediting the income handles the prescribed compliance.

For Form 79, the fund-level statement is verified by the authorised person and an accountant as prescribed. The Income Tax Department's guidance states that books, audited financial statements, income details, unit-holder information, distribution details, loss computations and registration documents should be available for the filing.

For Form 78, there is no separate set of documents to be filed because it is generated from the information contained in Form 79.

When Should an AIF Investor Receive the Income Statement?

Under the new rules, Form 78 should be furnished to each unit holder by 30 June of the financial year immediately following the tax year in which the income was paid or credited.

For an investor, the practical sequence should therefore be:

1. Wait for the AIF's tax statement/Form 78.
2. Verify the PAN and fund details.
3. Check income under each head.
4. Check capital-gain classification.
5. Check TDS.
6. Compare the statement against AIS/Form 26AS.
7. Use the information while preparing the ITR.

Do not rely solely on the amount actually received in your bank account. Under the pass-through provisions, income can have tax implications based on the statutory attribution mechanism, including deemed credit provisions. 

What Information Is Included in an AIF Tax Statement?

An AIF income statement should be read as a tax-classification document rather than simply a distribution statement.

The new Form 78 can contain:

• Investor name
• Investor PAN
• Address
• Tax year
• Investment fund name
• Fund PAN
• Income/loss details
• Date of payment or credit
• Head of income
• Capital-gain classification
• Applicable capital-gain codes
• Eligible deemed-loss information

The Income Tax Department's guidance states that Form 78 classifies income into categories such as Business/Profession, LTCG, STCG and Other Sources, including dividend and other income.

This makes the form particularly useful as an AIF investor tax statement when preparing the annual return.

How to Reconcile the AIF Statement with Form 26AS and AIS

One of the most important parts of AIF tax forms compliance is reconciliation.

Investors should compare the AIF statement against:

1. Form 26AS

Form 26AS primarily displays TDS/TCS-related information.

2. AIS

The Annual Information Statement is broader. It can include:

• TDS/TCS
• Specified Financial Transactions
• Tax payments
• Refunds/demands
• Dividend information
• Other reported financial information

The Income Tax Department specifically states that Form 26AS contains TDS/TCS-related data, while AIS provides broader information and allows taxpayer feedback. 

What should you compare?

Check:

AIF statement → AIS → Form 26AS → ITR

Compare:

• PAN
• Fund name
• Fund PAN
• Tax year
• Income amount
• Income head
• TDS amount
• Payment/credit date
• Capital-gain classification

This is especially important for AIF income Form 26AS reconciliation and AIF income in AIS verification.

Remember: a mismatch does not automatically mean the AIF statement is wrong. AIS and Form 26AS are reporting databases, while the fund statement provides the specific tax classification of the investor's pass-through income.

How Should AIF Income Be Reported in the ITR?

AIF income in ITR

Pass-through income should generally be reported according to the character and classification provided under the applicable investment-fund tax statement.

The basic principle is:

The character of the income generally flows through to the investor.

For example:

• Capital gain → capital gains reporting
• Interest/other-source income → Other Sources
• Dividend → dividend/Other Sources classification
• Eligible business/profession income → relevant business/profession reporting

The new Section 224 preserves the principle that income received by a unit holder from the investment fund is taxed as though the investment had been made directly by the unit holder, subject to the section's specific provisions. 

Therefore, how to report AIF income in ITR should not be answered simply by looking at the amount credited to your bank account. The classification in the fund's tax statement matters.

What Is Schedule PTI in an Income Tax Return?

Schedule PTI AIF

Schedule PTI stands for Pass Through Income.

It is the section used for reporting qualifying pass-through income from investment funds and business trusts.

The Income Tax Department's ITR-2 documentation identifies Schedule PTI as the place where pass-through income from investment funds/business trusts is reported. 

The existing ITR framework shows fields for:

• Investment entity
• Name of investment fund
• PAN of the fund
• Head of income
• Current-year income
• Share of current-year loss
• Net income/loss
• TDS

For an investor researching AIF pass-through income reporting, Schedule PTI is therefore a critical part of the tax-return workflow.

How Should AIF Capital Gains Be Reported?

AIF capital gains reporting

If your AIF statement reports capital gains, you should not simply combine them with all your other investment gains without checking the classification.

The statement may distinguish between:

• Short-term capital gains
• Long-term capital gains
• Section-specific categories
• Applicable capital-gain tax codes

The new Form 78 contains standardised capital-gain codes intended to make reporting in Schedule PTI and the capital-gains schedule more consistent. 

Therefore, AIF capital gains reporting should follow the classification in the applicable Form 78/Form 64C and the instructions for the relevant ITR.

A simplified workflow is:

Form 78 → Schedule PTI → relevant income schedule → tax computation

Do not assume that every AIF capital gain is taxed at the same rate. The applicable rate depends on the nature of the gain, asset, holding period and relevant provisions.

How Should Interest and Dividend Income Be Reported?

AIF interest income reporting

Interest income attributed through an AIF generally retains its character as income from the relevant source and should be reported accordingly.

For AIF interest income reporting, check:

• Amount of interest
• Relevant head of income
• TDS deducted
• Whether any special rate applies
• Whether the amount has already been reflected in AIS/26AS

AIF dividend income reporting

Dividend income should likewise be identified separately in the tax statement.

For AIF dividend income reporting, verify:

• Dividend amount
• Date/period
• TDS
• Classification in Form 78/Form 64C
• Reporting under the applicable ITR schedule

The new Form 78 expressly provides for Other Sources categories including dividend and other income.

How Is Business Income from an AIF Reported?

AIF business income reporting

This area requires particular attention.

Under the pass-through regime, business/profession income has special treatment. Section 224 provides that business/profession losses are not passed through to investors in the same manner as other income; such losses are dealt with at the fund level according to the statutory mechanism. 

Therefore, AIF business income reporting should be based on the classification shown by the fund and the applicable ITR instructions.

Investors should not automatically treat every AIF distribution as:

"Capital gain."

An AIF can generate multiple types of income, and the tax character is important.

How Should Pass-Through Losses Be Reported?

AIF loss reporting in ITR

Loss treatment is one of the most frequently misunderstood areas.

Under Section 224:

• Business/profession losses are generally retained at the investment-fund level and are not passed through to investors.
• Certain non-business losses may also be ignored for pass-through where the statutory 12-month holding condition is not satisfied.
• Historic losses accumulated as of 31 March 2019 have a specific statutory treatment for eligible unit holders. 

This means AIF loss reporting in ITR cannot be based simply on a negative number appearing in an investor statement.

You need to determine:

1. What type of loss is it?
2. Is it a business loss?
3. Is it another type of loss?
4. Was the relevant unit held for the required period?
5. Is it a historic loss covered by the specific transitional provision?

The new Form 78 continues to provide information regarding eligible deemed losses as of 31 March 2019.

Can AIF Income Appear Under More Than One Head of Income?

Yes.

This is actually one of the defining characteristics of pass-through taxation.

An AIF may generate:

• Capital gains
• Interest
• Dividend income
• Business/profession income
• Other-source income

The investor should not consolidate all of these into one generic "AIF income" figure.

Instead, the income generally needs to retain its appropriate character for tax reporting.

This is why the AIF tax forms contain head-wise classification rather than merely showing the gross amount distributed.

Which ITR Form May Apply to an AIF Investor?

ITR for AIF investor

The correct ITR for AIF investor depends on the investor's overall income profile, not merely on the fact that the person owns AIF units.

For example, under the currently published return framework:

ITR-1

ITR-1 is a highly restricted return. The Income Tax Department states that it cannot be used where the taxpayer has taxable capital gains outside the permitted scope, business/profession income, NRI/RNOR status and several other specified conditions. 

ITR-2

ITR-2 is generally relevant for individuals/HUFs who do not have income from profits and gains of business or profession and who are otherwise not eligible for ITR-1. It contains Schedule PTI. 

ITR-3

ITR-3 applies to individuals/HUFs having income under the head profits and gains of business or profession, subject to the applicable conditions. 

ITR-5 / ITR-6 / ITR-7

These may apply depending on the legal status and circumstances of the taxpayer. The new Form 78 guidance specifically identifies ITR-2, ITR-3, ITR-5, ITR-6 and ITR-7 as returns in which unit holders may report pass-through income through Schedule PTI.

Important: Do not choose an ITR form solely because you received Form 78. Your complete income profile and the applicable return instructions determine the correct form.

Can I File ITR-1 if I Have Pass-Through Income from an AIF?

Generally, you should not assume ITR-1 is available simply because your AIF income is small.

The current official ITR-1 eligibility excludes several situations relevant to AIF investors, including taxable short-term capital gains and income from business or profession. ITR-1 also does not provide the Schedule PTI functionality used for pass-through reporting. 

For an investor with qualifying pass-through income, the applicable ITR should instead be selected based on the nature of the income and the taxpayer's complete circumstances.

How Does Reporting Differ for NRI Investors?

NRI investors need to pay particular attention to:

• Residential status
• Source of income
• Applicable Indian tax provisions
• TDS
• DTAA eligibility
• Tax residency certificate requirements, where relevant
• The specific nature of AIF income

The pass-through principle does not mean that every amount connected with an AIF automatically has the same Indian tax treatment for residents and non-residents.

For non-residents, the applicable domestic provisions and treaty provisions need to be considered.

TDS also needs to be distinguished from the final tax liability. Under the new framework, Section 393 contains the relevant TDS provisions, including provisions concerning income from investment-fund units. 

For an NRI, professional tax advice is particularly advisable before filing where DTAA relief or foreign-source income is involved.

What Should You Do If the AIF Statement and AIS Do Not Match?

A mismatch is not necessarily a reason to change the tax statement immediately.

Follow this process:

Step 1: Check the PAN

Confirm that the fund has reported the correct investor PAN.

Step 2: Check the tax year

Make sure you are comparing the same tax year.

Step 3: Check the amount

Compare the income amount, not merely the bank credit.

Step 4: Check TDS

Compare the TDS in the AIF statement against Form 26AS.

Step 5: Check AIS

AIS may contain broader financial information than Form 26AS. 

Step 6: Contact the fund

If the discrepancy relates to the fund's reporting, request clarification or a corrected statement.

Step 7: Use AIS feedback where appropriate

The Income Tax Department allows taxpayers to provide feedback on information appearing in AIS. 

The safest approach is:

Do not blindly modify genuine income merely to make your return match an incorrect AIS entry.

Instead, maintain documentary evidence explaining the difference.

Does the AIF Tax Statement Show TDS Details?

Yes, the relevant investor statement and return schedules can include TDS-related information.

AIF TDS reporting

For an investor, AIF TDS reporting should be reconciled with:

• Form 78/Form 64C
• Form 26AS
• AIS
• Form 16A, where applicable
• ITR tax-paid/TDS schedule

The Income Tax Department describes Form 16A as the TDS certificate for income other than salary, while Form 26AS primarily displays TDS/TCS information. 

Importantly:

TDS deducted ≠ final tax liability.

TDS is generally a tax credit against the final liability, subject to the applicable rules.

AIF Tax-Reporting Checklist for Investors

Before filing your return, use this checklist for your AIF tax forms:

Documents

• Form 78 / Form 64C received
• AIF income statement
• Distribution statement
• Capital-gain statement
• TDS certificate/Form 16A, where applicable
• Form 26AS
• AIS
• Bank statements
• Investment transaction records
• Previous-year loss records, where relevant

Reconciliation

• Investor PAN is correct
• Fund PAN is correct
• Tax year is correct
• Income amount matches
• Capital gains classification checked
• Interest income checked
• Dividend income checked
• Business income checked
• Loss treatment checked
• TDS reconciled
• AIS differences investigated

ITR

• Correct ITR selected
• Schedule PTI completed where applicable
• Relevant income schedules completed
• Capital gains correctly classified
• TDS credit claimed correctly
• Losses reported only where permitted
• Supporting statements retained

AIF Tax Forms: A Simple Example

Suppose an investor receives an AIF statement showing:

The investor should not simply enter:

"AIF income = ₹7,50,000"

Instead, the investor should use the tax statement to determine the appropriate classification and report the relevant amounts through the prescribed pass-through and income schedules.

The exact tax payable will depend on the applicable provisions, tax rates, exemptions, deductions, losses and the taxpayer's complete return.

This illustrates why AIF tax forms are more than compliance paperwork—they are the bridge between the fund's tax computation and the investor's individual tax return.

Section 224 Investment Fund Reporting: What Investors Need to Know

The new Section 224 investment fund reporting framework is the legal foundation for the new Form 78/Form 79 mechanism.

Section 224 provides the pass-through framework under which income received or accruing to a unit holder from investments made through the investment fund is generally taxed in the same manner as if the investor had made the investment directly, subject to the section's specific provisions. 

The section also addresses:

• Income attribution
• Losses
• Business losses
• Historic losses
• Deemed credit
• Income character
• Fund-level taxation
• Statements to unit holders and tax authorities

This is why understanding Section 224 is essential to understanding the new AIF tax forms.

What Has Actually Changed in 2026?

The most important takeaway is that the form numbers have changed, but the investor workflow remains recognisable.

Earlier system

Section 115UB → Form 64D → Form 64C → Investor ITR

New system

Section 224 → Form 79 → Form 78 → Investor ITR

The Income Tax Department's guidance describes Form 78 as being automatically generated from Form 79, while Form 79 contains the consolidated fund-level information.

The new framework also introduces more structured reporting, including payment/credit dates and standardised capital-gain codes. 

Conclusion

AIF taxation can look complicated because investors often encounter multiple documents, multiple income heads and, now, two different generations of tax forms.

The key is to remember four numbers:

64C → Old investor statement

64D → Old fund-level statement

78 → New investor statement

79 → New fund-level statement

For tax years governed by the new Income-tax Act, 2025, Form 78 and Form 79 replace the corresponding Form 64C and Form 64D framework. Form 79 is filed by the investment fund, while Form 78 is generated from that filing and furnished to the individual unit holder. 

For investors, the real priority is not memorising form numbers. It is correctly connecting:

AIF Statement → Form 26AS → AIS → Schedule PTI → ITR → Final Tax Liability

If you invest in an AIF and want to avoid tax-reporting errors, always preserve your AIF statement, reconcile TDS and income with the tax portal, and report each income category according to its correct tax character.

Final Takeaway

If you remember only one framework from this article, remember:

Old tax year:Form 64D → Form 64C → ITR

New tax year:Form 79 → Form 78 → Schedule PTI → ITR

And always reconcile:

AIF statement + Form 26AS + AIS + ITR

The new AIF tax forms make the reporting architecture more structured, but investors still need to pay close attention to the nature of income, loss eligibility, TDS, tax year and correct ITR schedule.

Disclaimer: This article is for educational and informational purposes only and should not be treated as tax, legal or investment advice. Tax treatment can vary based on the AIF structure, investor status, nature of income, residential status and applicable tax provisions. Investors should consult a qualified tax professional/Chartered Accountant for their individual circumstances.

Research basis

The article has been prepared with reference to the Income Tax Department's official materials on the Income-tax Act, 2025, Income-tax Rules, 2026, Forms 78/79, Schedule PTI, Form 26AS/AIS and the transitional framework.