SPV + LLP, two-tier
A Special Purpose Vehicle is incorporated to own a single solar asset. Investors hold equity in the SPV through an LLP — the structure permitted by the Income Tax Act for pass-through profit distribution.
For sophisticated investors seeking returns beyond traditional fixed deposits and the volatility of equity markets, operational solar assets offer something distinct: contractually backed revenue from off-takers consuming power, structured through SEBI-aligned vehicles, with tax-efficient pass-through under §10(2A) and Year-1 depreciation shield under §32. Twenty-five-year revenue visibility. Real, physical assets. Quarterly distributions. Available to qualified investors at minimum participation of ₹25 lakh.
Trusted infrastructure execution since 1996 · BSNL · GAIL · Govt. of Odisha · 10+ MW installed
A Special Purpose Vehicle is incorporated to own a single solar asset. Investors hold equity in the SPV through an LLP — the structure permitted by the Income Tax Act for pass-through profit distribution.
The SPV signs Power Purchase Agreements with creditworthy off-takers — industrial captive consumers, commercial open-access buyers, and residential societies via VNM frameworks.
Revenue collected by the SPV flows to the LLP as profit, then to investors as profit distribution — tax-free in your hands under Section 10(2A) of the Income Tax Act.
Financial statements audited annually by an independent firm. Generation data captured directly from inverters and reconciled monthly. Investor dashboard for live verification.
Illustrative figures expressed as percentages of a representative capital base for structural explanation only. Actual returns, tax treatment, and depreciation eligibility depend on the investor's tax position, the entity through which participation is structured, and applicable rates in the financial year of investment. All claims are validated by the SPV's CA and the investor's CA prior to commitment. The investor deck contains the full numerical treatment by tranche.
The structure isn't novel. It uses two well-established provisions in combination — one for ongoing distribution, one for the underlying capital deployment.
Profits earned by an LLP are taxed at the LLP level. When those post-tax profits are distributed to partners, the distribution is exempt under Section 10(2A). The amount you receive each quarter does not attract further income tax in your individual return.
Solar generating equipment qualifies for 40% Accelerated Depreciation under Section 32 in Year 1. For investors structuring participation through eligible business entities, this depreciation shields the underlying capital deployment in the first year — a Year-1 economic effect captured at the SPV level and reflected in returns.
†Illustrative figures expressed as percentages of a representative capital base for structural explanation only. Actual returns, tax treatment, and depreciation eligibility depend on the investor's tax position, the entity through which participation is structured, and applicable rates in the financial year of investment. The investor deck contains the full numerical treatment by tranche.
The PPA is the contract. The tariff is fixed (or escalator-bound). The off-taker is creditworthy. Generation is captured directly from inverters and reconciled monthly. The revenue stream is visible — and verifiable — for the full asset life.
YR 01
Commissioning & depreciation shield
Asset commissioned. §32 AD claimed in full. First quarterly distribution.
YR 02 — 05
Steady-state generation
Generation stabilises at design output. Distributions cadence locks in.
YR 06 — 15
PPA term core
Contracted tariff & escalator. Off-taker creditworthiness reviewed annually.
YR 16 — 24
Long-tail visibility
PPA renewals, panel performance reconciled, residual depreciation claimed.
YR 25
Decommissioning & transfer
Asset transfer per SPA. Land & salvage reconciled. Final distribution.
Distributions are paid quarterly, post-OPEX and post-audit, into the partner's registered account.
Long-term Power Purchase Agreements with creditworthy industrial, commercial, and society off-takers.
Generation captured via Modbus/RTU from inverter, reconciled monthly, audited annually.
SPV collects PPA receipts monthly
Off-takers pay the SPV against contracted tariff and metered generation. Receipts reconciled against inverter data the same week they land.
CADENCE · MONTHLYLLP profit determined at quarter close
After O&M, insurance, and statutory dues, residual profit is computed. Independent CA signs the quarterly statement before distribution is authorised.
CADENCE · QUARTERLYPartner receives distribution, tax-free
Profit distribution is credited to the registered partner account within 15 working days of quarter close, exempt in the investor's return under §10(2A).
SETTLEMENT · 15 WORKING DAYSOur investor deck contains the complete picture: SPV structure, off-taker creditworthiness, tax architecture, generation projections, financial returns by tranche, and our execution credentials. It's reviewed by our CA and legal advisors before sharing. Available on request to qualified investors.