Section 10(23BBA) of the Income Tax Act provides a tax exemption for the income of any body or authority (whether or not a corporation) that is:
- Established, constituted, or appointed by or under a Central, State, or Provincial Act, and
- Responsible for the administration of public religious or charitable trusts or endowments, including places of worship like temples, gurdwaras, mosques, churches, synagogues, agiaries, etc., or
- Societies for religious or charitable purposes registered under the Societies Registration Act, 1860, or any other applicable law.
Important Caveat:
This exemption does not apply to the income of the trusts, endowments, or societies themselves—only to the body or authority administering them.
Example:
Suppose the State Religious Endowments Board is established under a State Act to manage temples and religious trusts across the state. It earns ₹2 crore annually from administrative fees, grants, and interest income.
Since:
- It is a statutory body,
- Its purpose is to administer public religious trusts, and
- It is not itself a trust or endowment,
its entire income is exempt under Section 10(23BBA).
But if one of the temples under its administration earns income from donations or property, that temple’s income is not exempt under this section—it would need to qualify separately under other provisions like Section 11 or 12.
