The Ministry of Finance has issued Notification No. 164/2025, dated November 26, 2025, granting income-tax exemption under Section 10(46A) of the Income-tax Act, 1961 to the Odisha Real Estate Regulatory Authority (RERA). The notification, issued using powers under clause (46A)(b), formally recognises the authority—constituted under the Real Estate (Regulation and Development) Act, 2016—as eligible for tax exemption beginning Assessment Year 2025-26. This benefit is conditional on the authority’s continued functioning under the RERA Act and its pursuit of one or more purposes specified in Section 10(46A)(a). The notification also includes an explanatory memorandum confirming that no party is adversely affected by its retrospective application. This measure reinforces the government’s approach of supporting statutory regulators by exempting income arising from their core regulatory functions, ensuring they can operate efficiently and independently in the public interest.
MINISTRY OF FINANCE
Department of Revenue
(Central Board of Direct Taxes)
Notification No. 164/2025 – Income Tax | Dated: 26th November, 2025
S.O. 5441(E).—In exercise of the powers conferred by sub-clause (b) of clause (46A) of section 10 of the Income-tax Act, 1961 (43 of 1961), (hereinafter referred to as “the Income-tax Act”), the Central Government hereby notifies “ Odisha Real Estate Regulatory Authority” (PAN: AAAGO0648F) (hereinafter referred to as “the assessee”), an authority constituted under the Real Estate (Regulation and Development) Act, 2016 (No. 16 of 2016), for the purposes of the said clause.
2. This notification shall be effective from the assessment year 2025-26, subject to the condition that the assessee continues to be an authority constituted under the Real Estate (Regulation and Development) Act, 2016 (No. 16 of 2016) with one or more of the purposes specified in sub-clause (a) of clause (46A) of section 10 of the Income-tax Act.
[Notification No. 164/2025 F. No. 300195/69/2024-ITA-I]
MEENAKSHI SINGH, Dy. Secy.
Explanatory Memorandum
It is certified that no person is being adversely affected by giving retrospective effect to this notification.
