The Central Government, through the Central Board of Direct Taxes (CBDT), Department of Revenue, Ministry of Finance, has notified the Baddi Barotiwala Nalagarh Development Authority (BBNDA), Himachal Pradesh, for exemption in respect of specified income under Section 10(46) of the Income-tax Act, 1961.
The notifications have been issued through Notification No. 82/2026 [S.O. 3798(E)] and Notification No. 83/2026 [S.O. 3799(E)], both dated 13 July 2026. Taken together, the two notifications provide for the applicability of the exemption to the Authority for Assessment Years 2019-20 to 2026-27, corresponding to Financial Years 2018-19 to 2025-26.
The Baddi Barotiwala Nalagarh Development Authority, bearing PAN AAALB0528J, is an authority constituted by the Government of Himachal Pradesh. The Central Government has notified the Authority for the purposes of Section 10(46) of the Income-tax Act, 1961 in respect of specified categories of income arising to it.
The specified income covered under the notifications 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 earned on bank deposits.
Notification No. 82/2026 [S.O. 3798(E)] provides for the exemption in respect of Assessment Years 2019-20, 2020-21, 2021-22, 2022-23 and 2023-24, corresponding to Financial Years 2018-19, 2019-20, 2020-21, 2021-22 and 2022-23, respectively.
Further, Notification No. 83/2026 [S.O. 3799(E)] extends the applicability to Assessment Years 2024-25, 2025-26 and 2026-27, corresponding to Financial Years 2023-24, 2024-25 and 2025-26, respectively. Thus, the two notifications together provide continuity of the notified tax treatment over eight assessment years, from Assessment Year 2019-20 through Assessment Year 2026-27.
The exemption is subject to prescribed conditions. The Baddi Barotiwala Nalagarh Development Authority shall not engage in any commercial activity; its activities and the nature of the specified income shall remain unchanged throughout the relevant financial years; and it shall file its return of income in accordance with the applicable provisions of Section 139(4C)(g) of the Income-tax Act, 1961.
The notifications further provide that failure to comply with the prescribed conditions may result in initiation of penal action under the provisions of the Income-tax Act, 1961 and withdrawal of the exemption granted under Section 10(46).
The notifications have been issued in the context of the transition from the Income-tax Act, 1961 to the Income-tax Act, 2025. While the Income-tax Act, 1961 has been repealed by Section 536(1) of the Income-tax Act, 2025, the saving and transitional provisions under Section 536(2) preserve the operation of relevant rights, liabilities, orders and proceedings pertaining to tax years beginning before 1 April 2026. Accordingly, the notifications have been issued in pursuance of the applicable transitional provisions of the Income-tax Act, 2025 for the purposes of Section 10(46) of the 1961 Act.
The Explanatory Memoranda accompanying the notifications state that no person’s interests are adversely affected by giving retrospective effect to the notifications from the relevant year of application filed before the Board or the Income Tax Department.
The combined notification framework provides clarity and continuity in the tax treatment of the specified income of the Baddi Barotiwala Nalagarh Development Authority for the period covering Financial Years 2018-19 to 2025-26, subject to continued compliance with the stipulated conditions.
The Notifications can be accessed at: https://a2ztaxcorp.net/wp-content/uploads/2026/07/NOTIFICATION-No.-82-2026.pdf , https://a2ztaxcorp.net/wp-content/uploads/2026/07/NOTIFICATION-No.-83-2026.pdf
