The Central Board of Direct Taxes (CBDT), under the Ministry of Finance, has issued Notification No. 59/2025 dated June 16, 2025, granting tax exemption to the Himachal Pradesh Board of School Education (HPBOSE), Dharamshala, under clause (46) of section 10 of the Income-tax Act, 1961. The exemption applies to specific income earned by the Board and has been given retrospective effect for Assessment Years 2020-21 to 2023-24, covering Financial Years 2019-20 to 2022-23.
Tax-Exempt Income Categories
As per the notification [S.O. 2689(E)], the following types of income arising to HPBOSE have been specified as exempt:
- Grants, advances, and receipts received from the State Government of Himachal Pradesh
- Fees or charges levied or received under the Himachal Pradesh Board of School Education Act, 1968
- Income from the sale of books and educational materials
- Interest earned on bank deposits
Conditions for Tax Exemption
The tax exemption is conditional and applies only if the Board:
- Does not engage in any commercial activity
- Maintains unchanged activities and income nature throughout the financial year
- Files income tax returns in accordance with clause (g) of sub-section (4C) of section 139 of the Income Tax Act
Retrospective Application and Legal Clarity
The notification clarifies that it will be deemed to have been applied from AY 2020-21 to AY 2023-24, effectively covering four financial years prior to the issuance of the notification. Additionally, the Explanatory Memorandum attached to the notification certifies that no individual or entity will be adversely affected by the retrospective application.
This move aligns with the government's continued efforts to clarify tax positions for statutory boards and government institutions, ensuring certainty in tax treatment of state-mandated educational bodies.
Official copy of the notification has also been attached
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