The Central Board of Direct Taxes (CBDT), Department of Revenue, Ministry of Finance, has issued Notification No. 95/2026 and Notification No. 96/2026, both dated 23 July 2026, notifying the Kerala Headload Workers Welfare Board, Kochi, bearing PAN AAAJK1176F, for exemption in respect of specified categories of income.
The two Notifications provide for the exemption under the respective provisions of the Income-tax Act, 1961 and the Income-tax Act, 2025, thereby ensuring continuity of the tax treatment applicable to the Board across the transition to the new income-tax legislation.
Under Notification No. 95/2026, issued as S.O. 4047(E), the Central Government has notified the Kerala Headload Workers Welfare Board, Kochi, for the purposes of Section 10(46) of the Income-tax Act, 1961. The Notification has been issued in pursuance of the savings and transitional provisions contained in Section 536(2) of the Income-tax Act, 2025.
Under Notification No. 96/2026, issued as S.O. 4048(E), the Board has been notified under Schedule III, Table Sl. No. 36, read with Section 11 of the Income-tax Act, 2025. This Notification governs the exemption available under the new statutory framework.
The specified income covered under both Notifications includes:
- Grants-in-aid and loans received from the Government;
- Levy collected under the Kerala Headload Workers Act, 1978, the Kerala Headload Workers Rules, 1981, and the schemes framed thereunder;
- Registration fees collected from members registered as beneficiaries;
- Deposits received from employers under the Kerala Headload Workers (Regulation of Employment and Welfare) Scheme, 1983;
- Contributions received from members;
- Interest on loans and advances given to employees of the Board and workers;
- Wages received from employers under the relevant provisions of the 1983 Scheme; and
- Interest earned on the aforesaid specified receipts.
The exemption will remain available subject to the condition that the Kerala Headload Workers Welfare Board, Kochi, does not engage in any commercial activity. Its activities and the nature of the specified income must also remain unchanged throughout the applicable financial or tax years.
The Board is further required to file its return of income in accordance with the applicable statutory provisions. Under Notification No. 95/2026, the return is required to be filed in accordance with Section 139(4C)(g) of the Income-tax Act, 1961. Under Notification No. 96/2026, the return is required to be filed in accordance with Section 263(9)(c)(xiii) of the Income-tax Act, 2025.
Failure to comply with the stipulated conditions may result in withdrawal of the exemption and initiation of proceedings or penal action under the applicable Income-tax Act.
Notification No. 95/2026 shall be deemed to apply to Assessment Years 2025-26 and 2026-27, corresponding to Financial Years 2024-25 and 2025-26. The Notification has been given retrospective effect, with the explanatory memorandum recording that such retrospective application does not adversely affect the interests of any person.
Notification No. 96/2026 shall apply to Tax Years 2026-27, 2027-28 and 2028-29 under the Income-tax Act, 2025.
The combined effect of the two Notifications is to provide a continuous exemption framework for the specified income of the Kerala Headload Workers Welfare Board, Kochi—first under the Income-tax Act, 1961, and subsequently under the Income-tax Act, 2025—subject to compliance with the prescribed conditions.
The Notifications can be accessed at: Notification No. 95/2026 , Notification No. 96/2026
