CBDT Approves UPASI Tea Research Foundation as Scientific Research Institution Under Income-Tax Act, 2025
Overview of the Notification
The Central Board of Direct Taxes (CBDT), through Notification No. 129 of 2026-Income Tax dated 28th September, 2026 (S.O. 5332(E)), has formally recognized UPASI Tea Research Foundation, Tamil Nadu (PAN: AAATU0634L) as an approved institution for scientific research under the newly enacted Income-tax Act, 2025. The approval places UPASI Tea Research Foundation within the category of "University, college or other institution" — specifically as an 'Other Institution' — for the purposes of Section 45(3)(a)(i) of the Income-tax Act, 2025.
The notification has been issued by the Ministry of Finance, Department of Revenue, under the authority conferred by Section 45(4)(b) of the Income-tax Act, 2025, and is to be read in conjunction with rules 32 and 34 of the Income-tax Rules, 2026.
Statutory Framework: Relevant Provisions
Section 45(3)(a)(i) — Income-tax Act, 2025
This provision governs the eligibility of donations made to approved universities, colleges, or other institutions engaged in scientific research for the purpose of tax benefits. An institution must receive formal recognition under Section 45(4)(b) before it can be treated as an eligible recipient under Section 45(3)(a)(i).
Section 45(4)(b) — Income-tax Act, 2025
This sub-section empowers the Central Government to approve institutions as eligible scientific research bodies. Such approval enables donors contributing to the approved institution to potentially claim associated tax benefits as prescribed under the Act.
Rules 32 and 34 — Income-tax Rules, 2026
The approval granted to UPASI Tea Research Foundation is subject to compliance with:
- Rule 32, which forms part of the procedural framework governing such approvals
- Rule 34, which lays down specific conditions that the approved institution must continuously satisfy throughout the period of validity of the notification
Validity Period of the Notification
The approval granted vide this notification is time-bound and shall remain in effect for the following tax years:
Tax Years 2026-2027 to 2030-2031