The Central Board of Direct Taxes (CBDT), under the Ministry of Finance, has issued two separate notifications on January 6, 2026, granting income tax exemption status to specified statutory authorities under Section 10(46A) of the Income-tax Act, 1961. Both notifications will be effective retrospectively from Assessment Year (AY) 2024-25, subject to prescribed conditions.
Mussoorie Dehradun Development Authority Granted Tax Exemption
Vide Notification No. 03/2026 (S.O. 87(E)), the Central Government has notified the Mussoorie Dehradun Development Authority (MDDA) (PAN: AAAAM4651Q) for the purposes of clause (46A) of Section 10 of the Income-tax Act.
The authority is constituted under the Uttar Pradesh Urban Planning Development Act, 1973 and is regulated under the Uttarakhand Urban and Country Planning Development (Amendment) Act, 2013.
The notification clarifies that the exemption will apply from AY 2024-25, provided the authority continues to operate under the said statutes and carries out one or more objectives specified under Section 10(46A)(a), which primarily relate to public utility and regulatory functions.
Joint Electricity Regulatory Commission Also Notified
In a separate Notification No. 02/2026 (S.O. 88(E)), the CBDT has extended similar income tax exemption to the Joint Electricity Regulatory Commission for the State of Goa and Union Territories (except Delhi) (PAN: AAAJJ0668D).
The Commission is constituted under the Electricity Act, 2003 and performs regulatory functions in the power sector. The exemption under Section 10(46A) will remain valid from AY 2024-25 onwards, subject to the condition that the Commission continues to fulfill statutory objectives outlined in the Act.
Retrospective Effect Clarified
An Explanatory Memorandum accompanying the notifications states that granting retrospective effect does not adversely affect any person, as the exemption is applicable from the year in which the applications were originally made before the Board or the Department.
Why This Matters
Section 10(46A) provides tax exemption to certain statutory authorities, boards, or bodies engaged in regulatory or public utility functions, provided they are notified by the Central Government. These notifications bring clarity and certainty to the tax position of such authorities and help avoid unnecessary litigation.
Official copy of the notifications have been attached
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