The Central Government has issued Notification No. 73/2026-Income Tax under section 10(46) of the Income-tax Act, 1961, read with the saving provisions of section 536 of the Income-tax Act, 2025, notifying the Mussoorie Dehradun Development Authority for exemption in respect of specified income. The exempt income includes Government grants, loans and advances, statutory fees and charges, income from disposal of movable and immovable properties, lease/rental income, and interest on bank deposits. The exemption is subject to the conditions that the Authority does not undertake any commercial activity, its activities and nature of income remain unchanged, and it files its income tax return under section 139(4C)(g) of the 1961 Act. Non-compliance may lead to withdrawal of the exemption and penal action under the Act. The notification applies retrospectively to Assessment Years 2022-23 and 2023-24, with the Government clarifying that the retrospective effect does not adversely affect any person.
MINISTRY OF FINANCE
(Department of Revenue)
(CENTRAL BOARD OF DIRECT TAXES)
Notification No. 73/2026-Income Tax | Dated: 2nd July, 2026
S.O. 3596(E).— Whereas, section 10 (46) of the Income-tax Act, 1961 (43 of 1961) provided for exemption of specified income of certain bodies or authorities or Boards or Trusts or Commissions as may be notified by the Central Government in the Official Gazette for the purposes of that section;
And whereas, the Income-tax Act, 1961 (43 of 1961) was repealed by section 536 (1) of the Income-tax Act, 2025 (30 of 2025);
And whereas, section 536(2)(a) and (b) of the Income-tax Act, 2025 (30 of 2025), inter alia, provides that irrespective of the repeal of the Income-tax Act, 1961 (43 of 1961) (hereinafter referred to as the Act of 1961) and subject to sub-section (4) thereof, nothing shall affect-
(i) the previous operation of the provisions of the Act of 1961 and any order or anything duly done or suffered thereunder; or
(ii) any right, privilege, obligation or liability acquired, accrued or incurred under the Act of 1961 or orders under that Act;
And whereas, section 536(2)(c) of the Income-tax Act, 2025 (30 of 2025) provides that the provisions of the Act of 1961 shall continue to apply to any proceeding pending on the date of commencement of the Income-tax Act, 2025 (30 of 2025) and to any proceedings initiated on or after the 1st April, 2026 (including notices, assessment, reassessment, recomputation, rectification, penalty, reference, revision and appeals) in respect of any tax year beginning before the 1st April, 2026 and such proceedings shall be carried out as per the procedure specified in the Act of 1961;
And whereas, section 536(2)(e) of the Income-tax Act, 2025 (30 of 2025) provides that any proceeding pending on the date of its commencement before any income-tax authority or any other authority constituted under the repealed Income-tax Act, Appellate Tribunal, or any court, by way of application, appeal, reference or revision or by any other means, shall be continued and disposed of as if this Act had not been enacted;
Now, therefore, in pursuance of the provisions of section 536(2)(a) to (c) and (e) of the Income-tax Act, 2025 (30 of 2025), the Central Government hereby notifies, for the purposes of section 10 (46) of the Act of 1961, ‘Mussoorie Dehradun Development Authority’ (PAN: AAAAM4651Q), an authority constituted by the State Government of Uttarakhand, in respect of the following specified income arising to that authority, namely:-
(a) Grants/loans/ advances received from Government of Uttarakhand.
(b) Fees/charges/income (by whatever name called) levied as per Uttarakhand Urban and Country Planning and Development Act, 1973
(c) Income from disposal of lands, buildings and other movable and immovable properties.
(d) Income from lease/rent; and
(e) Interest on bank deposits.
2. This notification shall be effective subject to the conditions that the Mussoorie Dehradun Development Authority –
(a) shall not engage in any commercial activity;
(b) its activities and the nature of the specified income shall remain unchanged throughout the financial years; and
(c) shall file return of income in accordance with the provisions of section 139(4C) (g) of the Act of 1961.
3. Failure to comply with these conditions shall result in the initiation of penal actions under the provisions of the Act of 1961, and withdrawal of exemption granted under section 10(46) of the Act of 1961.
4. This notification shall be deemed to have been applied for assessment years 2022-2023 and 2023-24 relevant for the financial years 2021-22 and 2022-2023.
[Notification No. 73/2026 F. No. 300196/32/2021-ITA-I]
HARDEV SINGH, Under Secy., ITA-I
Explanatory Memorandum
It is certified that the interests of no person are being adversely affected by giving retrospective effect [with effect from the year of application filed before the Board or Income-tax Department] to this notification.
