Income Tax Exemption Notified for Tamil Nadu e-Governance Agency under Section 10(46)
The Ministry of Finance, through the Central Board of Direct Taxes (CBDT), has issued an important notification granting income tax exemption to the Tamil Nadu e-Governance Agency (TNeGA) under Section 10(46) of the Income-tax Act, 1961.
The notification was issued on 21st January, 2026 and is relevant for government agencies, professionals, and stakeholders involved in e-governance and public sector projects.
Let’s understand what this notification means, which incomes are covered, and the conditions attached to the exemption.
What is Section 10(46)?
Section 10(46) of the Income-tax Act allows exemption of income earned by certain authorities, boards, or bodies set up by the Central or State Government, provided the income arises from non-commercial activities carried out in furtherance of public objectives.
Who Has Been Notified?
The Central Government has notified:
Tamil Nadu e-Governance Agency (TNeGA)
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Formed by: Government of Tamil Nadu
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PAN: AABTT6381N
TNeGA plays a key role in implementing digital governance initiatives and citizen-centric online services across the state.
Types of Income Eligible for Exemption
The exemption under Section 10(46) applies only to specified income, which includes:
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Government Grants & Contributions
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Recurring grants or grants-in-aid received from the Government of Tamil Nadu or other specified authorities for operational expenses.
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Service Charges via Common Service Centres (CSCs)
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Charges collected for providing online services to citizens through CSCs.
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IT & Software-Related Services
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Service charges from:
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Software development projects
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IT consultancy services
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Projects undertaken for other State Government departments, PSUs, or statutory boards
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Interest earned on advance funds received for such projects until disbursement.
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Dividend Income
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Dividend received from CSC e-Governance Services India Limited (CSC-SPV).
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Administrative Charges on UIDAI Projects
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Administrative costs on PEC grants released by UIDAI to enrolment agencies, where TNeGA acts as the enrolment registrar.
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Online Examination Revenue
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Revenue sharing income from conducting online examinations for State Government departments, PSUs, or statutory bodies.
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Incidental or Ancillary Income
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Any other income that may arise in future, provided it is incidental to or in furtherance of TNeGA’s objectives.
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Interest Income
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Interest earned on any of the above specified incomes.
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Conditions Attached to the Exemption
The exemption is not automatic and is subject to strict compliance with the following conditions:
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No Commercial Activity
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TNeGA must not engage in any commercial or profit-oriented activities.
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Nature of Activities Must Remain the Same
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The activities and nature of income must remain unchanged across the financial years.
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Mandatory Filing of Return
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The agency must file its income tax return as per Section 139(4C)(g) of the Income-tax Act.
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???? Non-compliance with these conditions may lead to:
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Penal action under the Income-tax Act, and
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Withdrawal of exemption granted under Section 10(46).
Period for Which Exemption Applies
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The notification is retrospectively applicable for:
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AY 2024-25
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AY 2025-26
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It will also apply prospectively for:
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AY 2026-27
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AY 2027-28
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AY 2028-29
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The Explanatory Memorandum clarifies that no person is adversely affected due to the retrospective application of this notification.
Key Takeaway
This notification reinforces the government’s intent to support e-governance initiatives by providing tax relief to agencies working exclusively for public welfare without a commercial motive.
