Tax Exemption Under Section 10(46): CBDT Notifies Odisha Joint Entrance Examination Committee Amidst Legislative Transition

The Central Board of Direct Taxes (CBDT) has recently issued a crucial directive, providing substantial tax relief to a prominent state-established educational body. Through Notification No. 109/2026-Income Tax, issued on the 4th of August 2026, the apex direct tax administrative body has officially recognized the Odisha Joint Entrance Examination Committee (PAN: AAAGO0158G) for specific exemptions. This recognition is granted under the purview of Section 10(46) of the Income-tax Act, 1961, read harmoniously with the transitional provisions outlined in the newly enacted Income-tax Act, 2025.

This notification is particularly significant as it navigates the complex transitional phase between the old and new tax regimes. It clarifies the tax-exempt status of specific revenue streams generated by the state committee, provided the assessee strictly adheres to a set of predefined statutory conditions.

Understanding the Legislative Framework and Transition

The landscape of direct taxation is undergoing a monumental shift with the introduction of the Income-tax Act, 2025. To understand the gravity of this notification, one must delve into the interplay between the repealed statutes and the new legislative framework.

The Role of Section 10(46) of the Income-tax Act, 1961

Historically, Section 10(46) of the Income-tax Act, 1961 has served as a vital tool for the Central Government to exempt specific income streams of bodies, authorities, boards, trusts, or commissions established by the Central or State Governments. The core objective of this provision is to ensure that entities formed with the primary goal of public welfare, and not for profit generation, are not burdened by direct tax liabilities on their legitimate operational income.

With the advent of the new tax code, the Income-tax Act, 1961 was formally repealed by Section 536(1) of the Income-tax Act, 2025 (30 of 2025). However, to prevent administrative chaos and protect accrued rights, the legislature incorporated robust saving clauses.