The Ministry of Finance, Department of Revenue, through a series of notifications issued on November 26, 2025, has granted income-tax exemptions to three statutory bodies under various provisions of Section 10 of the Income-tax Act, 1961. The notifications, published by the Central Board of Direct Taxes (CBDT), cover the State Pollution Control Board, Odisha (SPCB Odisha), the Haryana State Board of Technical Education (HSBTE), Panchkula, and the Odisha Real Estate Regulatory Authority (Odisha RERA).
These exemptions aim to ensure smoother functioning of statutory bodies by freeing key streams of income from taxation, while also requiring adherence to compliance conditions.
1. SPCB Odisha Notified Under Section 10(46)
The Central Government has notified State Pollution Control Board, Odisha (PAN: AAALS2490J) under Section 10(46), exempting several categories of income received by the authority.
Exempt Income Categories Include
- Statutory consent and authorisation fees under the Water Act, 1974 and Air Act, 1981
- Penalties, levies, and statutory recoveries
- Grants-in-aid from Central and State Governments
- Grants received as a nodal agency
- Contributions for environmental studies and research
- Miscellaneous income such as scrap sale, tender fees, RTI fees, analysis charges, consultant empanelment fees, forfeiture of bank guarantees, etc.
- Interest earned on the above incomes
Conditions for Exemption
SPCB Odisha must:
- Not engage in any commercial activity
- Maintain the nature of activities and exempt incomes without change
- File income tax returns as per Section 139(4C)(g)
Applicable Period
The exemption applies retrospectively from FY 2023-24 to FY 2025-26 and prospectively from FY 2026-27 to FY 2027-28 linked to AYs 2024-25 to 2028-29.
CBDT has certified that no person is adversely affected by granting retrospective effect.
2. HSBTE Panchkula Notified Under Section 10(46)
The Haryana State Board of Technical Education (HSBTE), Panchkula (PAN: AAAGT0008A), has also been notified for income-tax exemption under Section 10(46).
Exempt Income Categories Include
- Grants, assignments, and contributions from Central & State Governments
- Affiliation, examination, migration, transcription and other administrative fees
- Royalties, charges and penalties
- Donations, bequests, and endowments
- Sale proceeds of securities and income from properties vested in HSBTE
- Interest earned on bank deposits
Conditions for Exemption
HSBTE must:
- Avoid commercial activities
- Keep activities and income categories unchanged
- File income tax returns as per Section 139(4C)
Applicability
The notification applies retrospectively from AY 2025-26 (FY 2024-25) and is valid up to AY 2029-30 (FYs 2025-26 to 2028-29).
CBDT has again clarified that the retrospective application causes no adverse impact on taxpayers.
3. Odisha RERA Notified Under Section 10(46A)
In a separate notification, the Odisha Real Estate Regulatory Authority (Odisha RERA) (PAN: AAAGO0648F) has been notified under Section 10(46A) of the Income-tax Act.
This provision grants exemption to income of RERA authorities constituted under the Real Estate (Regulation and Development) Act, 2016, provided they continue to operate for the purposes specified under Section 10(46A)(a).
Effective Date
The exemption applies from Assessment Year 2025-26 onwards.
CBDT has again confirmed that the notification's retrospective effect causes no adverse taxpayer implications.
Strengthening Statutory Governance Through Tax Relief
These notifications reflect the Government's policy of strengthening statutory institutions by ensuring that incomes arising from regulatory, administrative, and public-interest functions remain tax-exempt. The exemptions enable such authorities to reinvest funds into public service delivery instead of tax outflows.
The retrospective applicability across multiple notifications ensures continuity in tax treatment and aligns with past practice for similar bodies.
Official copy of the notifications have been attached
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