Tax Exemptions for Funds/Institutions of National Importance [Section 10(23C) & Rules 2C/2CA]

1. Covered Entities (Section 10(23C))

The following enjoy 100% tax exemption on their income:

  • Funds/institutions for:
    • Charitable purposes (iv)
    • Religious purposes (v)
  • Key institutions:
    • Educational (iiiab)
    • Medical (iiiac)
    • Housing (iiiad)
    • Sports (iiiae)
  • Specifically notified:
    • IITs/IIMs/AIIMS (vi)
    • National importance institutions (viia)

2. Mandatory Conditions

For continuing exemption:

  • Registration: Must file Form 10BB (new)
  • Income Application: 85% spent on objectives
  • Audit: Compulsory if income >₹5 lakh
  • Norms: Follow Rule 2C/2CA conditions

3. Investment Restrictions (Rule 2CA)

Permitted modes:

  • Govt securities
  • Scheduled bank deposits
  • Public sector bonds
  • Approved mutual funds

4. Key Differences from Section 11

PARAMETER SECTION 10(23C) SECTION 11
Applicability Specific elite institutions General charitable trusts
Registration Approval from CBDT CIT(E) registration
Donation Tax 80G not required 80G needed
Audit Limit ₹5 lakh ₹5 lakh

5. Compliance Requirements

  • Annual Filing: ITR-7 with audit report (Form 10BB)
  • Disclosures: Foreign contributions (if FCRA registered)
  • Prohibitions: No trustee benefits (Section 13 applies)
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