The Central Board of Direct Taxes (CBDT) has issued Notification Nos. 106/2026 to 110/2026, all dated August 04, 2026, notifying specified income of the Noida Special Economic Zone Authority and the Odisha Joint Entrance Examination Committee for tax exemption under the applicable provisions of the Income-tax Act, 1961 and the Income-tax Act, 2025.
The notifications have been issued in two sets to address the relevant periods governed by the erstwhile Income-tax Act, 1961 and subsequent tax years governed by the Income-tax Act, 2025. The notifications cover only the specified categories of income mentioned therein and do not provide a general exemption in respect of all income of the notified bodies.
Tax exemption for Noida Special Economic Zone Authority
Under Notification No. 106/2026, vide S.O. 4318(E) and F. No. 300196/65/2018-ITA-I, the Central Government has notified the Noida Special Economic Zone Authority, PAN AAALN0639A, for the purposes of Section 10(46) of the Income-tax Act, 1961. The notification applies to Assessment Years 2019-20 to 2023-24, corresponding to Financial Years 2018-19 to 2022-23.
Further, Notification No. 107/2026, vide S.O. 4319(E) and F. No. 300196/65/2018-ITA-I, extends the notification of specified income of the Noida Special Economic Zone Authority under Section 10(46) of the Income-tax Act, 1961 to Assessment Years 2024-25 to 2026-27, corresponding to Financial Years 2023-24 to 2025-26.
For the period governed by the Income-tax Act, 2025, the Central Government has issued Notification No. 108/2026, vide S.O. 4320(E) and F. No. 300196/65/2018-ITA-I. The notification has been issued under Section 11 read with Schedule III, Table Serial No. 36, of the Income-tax Act, 2025 and will apply to Tax Years 2026-27 and 2027-28.
The specified income of the Noida Special Economic Zone Authority covered by these notifications includes lease rent; interest received from banks on fixed deposits; receipts from identity cards and permit fees; allotment fees relating to standard-design factories; auction or bid amounts in respect of vacant plots and buildings; transfer charges relating to plots and buildings; fees for issuing Form-I for exemption of building plans; processing fees for approval of building plans; site-usage charges received from service providers; and income from the sale of miscellaneous scrap or waste.
Tax exemption for Odisha Joint Entrance Examination Committee
Under Notification No. 109/2026, vide S.O. 4321(E) and F. No. 300196/39/2025-ITA-I, the Central Government has notified the Odisha Joint Entrance Examination Committee, PAN AAAGO0158G, for the purposes of Section 10(46) of the Income-tax Act, 1961. The notification will be deemed to apply to Assessment Year 2026-27, corresponding to Financial Year 2025-26.
For subsequent tax years, Notification No. 110/2026, vide S.O. 4322(E) and F. No. 300196/39/2025-ITA-I, has been issued under Section 11 read with Schedule III, Table Serial No. 36, of the Income-tax Act, 2025. The notification will apply to Tax Years 2026-27 to 2029-30.
The specified income of the Odisha Joint Entrance Examination Committee covered by the notifications comprises examination fees collected from candidates, counselling and application-processing fees, and interest earned on bank deposits.
Conditions attached to the exemptions
The exemptions are subject to the condition that the Noida Special Economic Zone Authority and the Odisha Joint Entrance Examination Committee shall not engage in any commercial activity. Their activities and the nature of the specified income must also remain unchanged throughout the relevant financial years or tax years.
The notified bodies are required to file their returns of income in accordance with the applicable provisions. For periods governed by the Income-tax Act, 1961, returns are to be filed in accordance with Section 139(4C)(g). For periods governed by the Income-tax Act, 2025, returns are to be filed in accordance with Section 263(9)(c)(xiii).
Failure to comply with the prescribed conditions may result in withdrawal of the exemption and initiation of penal or other proceedings under the applicable Income-tax Act.
Notifications Nos. 106/2026, 107/2026 and 109/2026 have been given retrospective effect for their respective periods. The explanatory memoranda accompanying these notifications certify that such retrospective application does not adversely affect the interests of any person.
The five notifications collectively clarify the tax treatment of the specified income of the two bodies for the relevant periods and provide statutory continuity during the transition from the Income-tax Act, 1961 to the Income-tax Act, 2025.
