The Central Board of Direct Taxes (CBDT) through Notification No. 139/2025 dated 22 August 2025 has granted income-tax exemption under Section 10(46) of the Income-tax Act, 1961 to the Credit Guarantee Fund Trust for Animal Husbandry and Dairying (PAN: AACTC8610N). The Trust, established by the Central Government under the Atma Nirbhar Bharat Abhiyan package through the Department of Animal Husbandry and Dairying, is notified for specified income categories including guarantee fees received from eligible lending institutions, income from mutual funds, miscellaneous income, and interest from banks/financial institutions. The exemption is subject to conditions that the Trust does not undertake commercial activity, the specified income categories remain unchanged across financial years, and it files its return of income as per Section 139(4C)(g). The notification applies retrospectively for Assessment Year (AY) 2025–26 (relevant to FY 2024–25) and prospectively for AYs 2026–27 to 2029–30 (relevant to FYs 2025–26 to 2028–29). The government clarified that the retrospective application does not adversely affect any person. This exemption ensures that the Trust’s income arising from its defined activities in support of animal husbandry and dairying credit guarantee functions will not be subject to tax, aligning with its public welfare purpose.
MINISTRY OF FINANCE
(Department of Revenue)
(CENTRAL BOARD OF DIRECT TAXES)
Notification No. 139/2025-Income Tax | Dated:22nd August, 2025
S.O. 3854(E).— In exercise of the powers conferred by clause (46) of section 10 of the Income-tax Act, 1961 (43 of 1961), the Central Government hereby notifies for the purposes of the said clause, ‘Credit Guarantee Fund Trust for Animal Husbandry and Dairying (PAN: AACTC8610N)’, a Trust constituted by Central Government, as part of the Prime Minister’s Atma Nirbhar Bharat Abhiyan stimulus package by Department of Animal Husbandary and Dairying, Ministry of Fisheries, Animal Husbandary and Dairying, Govt. of India, in respect of the following specified income arising to the said Trust, namely:
i) Guarantee Fees from ELI (Eligible Lending Institutions)
ii) Income from Mutual Funds
iii) Miscellaneous Income
iv) Interest income from banks/financial institutions.
2. This notification shall be effective subject to the conditions that ‘Credit Guarantee Fund Trust for Animal Husbandry and Dairying’–
(a) shall not engage in any commercial activity;
(b) 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 provision of clause (g) of sub-section (4C) of section 139 of the Income-tax Act, 1961.
3. This notification shall be deemed to have been applied for assessment years 2025-2026 relevant for the financial years 2024-2025 and shall be applicable for assessment years 2026-2027,2027-2028, 2028-2029 & 2029-2030 relevant for the financial years 2025-2026, 2026-2027,2027-2028 & 2028-2029.
[Notification No. 139/2025/F. No. 300196/6/2025-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.
