The Central Government, on the recommendation of the Central Board of Direct Taxes (CBDT), has issued two separate notifications notifying specified authorities for the purposes of income tax exemption under clause (46A) of section 10 of the Income-tax Act, 1961.
Kota Development Authority Notified
Vide Notification No. 04/2026, issued as S.O. 100(E) dated 7th January, 2026, the Central Government has notified the Kota Development Authority (PAN: AAAJK2043D), an authority constituted under the Kota Development Authority Act, 2023 (Act No. 31 of 2023), for the purposes of clause (46A) of section 10 of the Income-tax Act, 1961.
The notification shall be effective from the Assessment Year 2025-26, subject to the condition that the Authority continues to function with one or more of the specified purposes mentioned under sub-clause (a) of clause (46A) of section 10 of the Act.
Gorakhpur Industrial Development Authority Notified
In a similar move, vide Notification No. 05/2026, issued as S.O. 101(E) dated 7th January, 2026, the Central Government has notified the Gorakhpur Industrial Development Authority (PAN: AAALG1185A), constituted under the Uttar Pradesh Industrial Area Development Act, 1976 (U.P. Act No. 6 of 1976), for the same purpose.
This notification is also effective from the Assessment Year 2025-26, subject to the Authority continuing to meet the conditions laid down under sub-clause (a) of clause (46A) of section 10 of the Income-tax Act, 1961.
No Adverse Retrospective Impact
Both notifications include an Explanatory Memorandum clarifying that granting retrospective effect, i.e., from the year in which the application was made before the Board/Department, will not adversely affect any person.
These notifications aim to provide tax certainty and facilitate the effective functioning of statutory development authorities engaged in public infrastructure and industrial development activities.
The Notifications can be accessed at: https://a2ztaxcorp.net/wp-content/uploads/2026/01/CBDT-NN-04-05-2026.pdf
