Summary: The content is a regulatory update. CBDT Notification No. 82/2026-Income Tax dated 13 July 2026, issued under the transitional provisions of section 536(2)(a) to (c) and (e) of the Income-tax Act, 2025, notifies the Baddi Barotiwala Nalagarh Development Authority (PAN AAALB0528J), constituted by the Government of Himachal Pradesh, for the purposes of section 10(46) of the Income-tax Act, 1961. The specified exempt income includes grants received from the Central Government or the Government of Himachal Pradesh, revenue receipts under the Himachal Pradesh Town and Country Planning Act, 1977, and interest on bank deposits. The notification is subject to conditions that the Authority must not engage in commercial activity, its activities and the nature of the specified income must remain unchanged throughout the financial years, and it must file its return of income under section 139(4C)(g) of the Income-tax Act, 1961. Non-compliance may result in penal action under the Act of 1961 and withdrawal of the exemption. The notification is deemed applicable for Assessment Years 2019-20 to 2023-24, and the explanatory memorandum states that no person’s interests are adversely affected by its retrospective effect.
MINISTRY OF FINANCE
(Department of Revenue)
(CENTRAL BOARD OF DIRECT TAXES)
Notification No. 82/2026-Income Tax |Dated: 13th July, 2026
S.O. 3798(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And whereas, the Income-tax Act, 1961 (43 of 1961) was repealed by section 536(1) of the Income-tax Act, 2025 (30 of 2025);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, “Baddi Barotiwala Nalagarh Development Authority (PAN AAALB0528J)”, an authority constituted by the State Government of Himachal Pradesh, in respect of the following specified income arising to that Authority, namely:-
a. grants received from the Central Government or the State Government of Himachal Pradesh;
b. revenue receipts under the Himachal Pradesh Town and Country Planning Act, 1977 (Himachal Pradesh Act 12 of 1977); and
c. interest on bank deposits.
2. This notification shall be effective subject to the conditions that the Baddi Barotiwala Nalagarh 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 the assessment years 2019-20, 2020-21, 2021-22, 2022-23 and 2023-24 relevant to the financial years 2018-19, 2019-20, 2020-21, 2021-22 and 2022-23.
[No. 82 /2026/F. No. 300196/45/2025-ITA-I]
HARDEV SINGH, Under Secy.
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.
