CBDT approval to Ashoka Trust for Research in Ecology and the Environment (ATREE) for Scientific Research: Key tax implications

The Central Board of Direct Taxes has issued a notification approving Ashoka Trust for Research in Ecology and the Environment, Bengaluru (ATREE) as an eligible “other institution” for Scientific Research within the broader category of University, college or other institution. This approval is granted under section 45(3)(a)(i) read with section 45(4)(b) of the Income-tax Act, 2025, and in terms of rules 32 and 34 of the Income-tax Rules, 2026.

The notification has important consequences both for the institution and for assessees who contribute donations to it, particularly in relation to compliance obligations, documentation, and the period for which the approval remains valid.

Statutory framework governing the approval

Relevant provisions of the Income-tax Act, 2025

The notification specifically invokes:

  • section 45(3)(a)(i) of the Income-tax Act, 2025; and
  • section 45(4)(b) of the Income-tax Act, 2025.

Together, these provisions deal with:

  • recognition of certain entities (such as Universities, colleges, and “other institutions”) for Scientific Research;
  • tax benefits linked to donations made for Scientific Research; and
  • conditions and procedural requirements that such approved entities must meet in order to retain their notified status.

Applicable Income-tax Rules, 2026

The notification also relies upon:

  • rule 32 of the Income-tax Rules, 2026; and
  • rule 34 of the Income-tax Rules, 2026, read with rule 31.

These rules collectively set out:

  • eligibility conditions and procedural norms for institutions approved for Scientific Research;
  • reporting and filing obligations relating to donations;
  • formats of forms and certificates to be used for reporting and for issuing confirmations to donors.

Core content of the CBDT notification

Nature of approval granted to ATREE

Through Notification No. 123 of 2026-Income Tax, dated 28th September, 2026, and published as S.O. 5326(E), the Central Government, acting under section 45(4)(b) of the Income-tax Act, 2025, has:

  • Approved Ashoka Trust for Research in Ecology and the Environment, Bengaluru, bearing PAN: AAATA3176D;
  • Classified it as an “other institution” under the overarching category of University, college or other institution;
  • Recognized it specifically for Scientific Research purposes;
  • Declared that this approval is for the purposes of section 45(3)(a)(i) of the Income-tax Act, 2025, read with rules 32 and 34 of the Income-tax Rules, 2026.

This recognition enables ATREE to receive donations that may qualify for specified tax treatment under the relevant statutory provisions, subject to the conditions laid down in the notification.

Approval period

The notification expressly provides that it shall remain effective for the following tax years:

  • From tax year 2026-27
  • Up to and including tax year 2030-31

Accordingly, for donations made to ATREE during any of the tax years 2026-27, 2027-28, 2028-29, 2029-30, and 2030-31, subject to compliance with the prescribed conditions, the institution’s approved status will be available, and the related tax treatment can be considered by the donor assessee in accordance with the Act and Rules.

Conditions attached to the approval

The approval is not unconditional. It is specifically stated that the notification applies to Ashoka Trust for Research in Ecology and the Environment, Bengaluru (PAN: AAATA3176D) subject to certain conditions.

Continuation as SIRO