Exemption from Tax Deducted/Collected at Source (TDS/TCS) to the International Rice Research Institute (IRRI).
Summary: The Central Government, through CBDT Notification No. 138/2026 dated 28 October 2026, has notified that the provisions of Chapter XIX of the Income-tax Act, 2025 shall not apply to payments received by the International Rice Research Institute (IRRI). Issued as S.O. 5855(E), the notification exercises the power conferred by section 400(1) of the Act. The operative relief is framed by reference to payments received by IRRI and the non-application of Chapter XIX to those payments. It does not state a separate exemption from every provision of the Income-tax Act or extend the relief to other institutions. The notification expressly makes this treatment subject to the conditions specified in the United Nations (Privileges and Immunities) Act, 1947, read with Ministry of External Affairs Notification S.O. 3230(E) dated 3 October 2017. Accordingly, the exclusion must be read together with those conditions rather than as an unconditional relaxation. The notification itself does not reproduce the conditions contained in the referenced legislation and instrument. Its commencement clause provides that it takes effect on the date of publication in the Official Gazette; no separate retrospective commencement date or expiry date is specified in the supplied text. The notification therefore establishes the recipient-specific exclusion while retaining the expressly referenced privileges and immunities conditions.
MINISTRY OF FINANCE
(Department of Revenue)
(CENTRAL BOARD OF DIRECT TAXES)
Notification No. 138/2026- Income Tax | Dated: 28th October, 2026
S.O. 5855(E).—In exercise of the powers conferred by sub-section (1) of section 400 of the Income-tax Act, 2025 (30 of 2025), the Central Government hereby notifies that the provisions of Chapter XIX of the said Act shall not apply to payments received by International Rice Research Institute (IRRI). The above notification is subject to the conditions specified in the United Nations (Privileges and Immunities) Act, 1947 (46 of 1947) read with notification number S.O. 3230(E), dated the 3rd October, 2017, issued by the Ministry of External Affairs, Government of India.
2. This notification shall come into force on the date of its publication in the Official Gazette.
[Notification No. 138/2026/F.No. 275/44/2026-IT(B)]
RAJENDRA KUMAR MEENA, Under Secy.
