“Qualifying share” definition of section 12J of ITA

“qualifying share” means an equity share held by a venture capital company which is issued to that company by a qualifying company, and does not include any share which-

(b)     would have constituted a hybrid equity instrument, as defined in section 8E(1), but for the three-year period requirement contemplated in paragraph (b)(i) of the definition of “hybrid equity instrument” in that section; or

[Paragraph (b) substituted by section 29 of Act 23 of 2018 effective on 1 January 2019 applies in respect of years of assessment commencing on or after that date]

(c)     constitutes a third-party backed share as defined in section 8EA(1);