The Central Board of Direct Taxes (CBDT) has notified income tax exemption under Section 10(46) of the Income-tax Act, 1961 for the Baddi Barotiwala Nalagarh Development Authority’s specified income.
The exemption is applicable retrospectively for assessment years from 2014-2015 to 2018-2019.
As per the notification, the following income sources of the Authority will be tax-exempt:
- Grants received from the Central and Himachal Pradesh State Governments,
- Revenue generated under the Himachal Pradesh Town and Country Planning Act, 1977,
- Interest earned on bank deposits.
However, the exemption is subject to strict compliance with conditions laid down in the notification. The Authority must:
- Not engage in any commercial activity,
- Maintain consistency in its activities and the nature of income, and
- File its income tax return as mandated under Section 139(4C)(g) of the Income-tax Act.
The retrospective benefit will apply to financial years 2013-14 through 2017-18. Importantly, the government has clarified that granting this retrospective exemption will not adversely affect any person, as stated in the Explanatory Memorandum attached to the notification.
Notification Details
Notification No. 114/2025
Date: 14th July, 2025
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Mariya is the Senior Editor at Juris Hour. She has 5+ years of experience on covering tax litigation stories from the Supreme Court, High Courts and various tribunals including CESTAT, ITAT, NCLAT, NCLT, etc. Mariya graduated from MLSU Law College, Udaipur (Raj.) with B.A.LL.B. and also holds an LL.M. She started as a freelance tax reporter in the leading online legal news companies like LiveLaw & Taxscan.