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ITA 1961 → DTC 2025Exemptions

Section 10(23C) Section 12

Income of Educational and Medical Institutions

RetainedHigh - Massively simplifies compliance for schools and hospitals.

Quick Answer

Section 10(23C) of the Income Tax Act, 1961 (Income of Educational and Medical Institutions) corresponds to Section 12 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective 1st April 2026. Status: Retained.

Old Law (ITA 1961)Ch: III

Sec 10(23C)

Provision Summary

Exempts income of universities, hospitals, and educational institutions existing solely for education/philanthropy and not for profit.

New Law (DTC 2025)Ch: III

Sec 12

Provision Summary

Retained but heavily regulated. Completely aligned with the registration and compliance framework of Section 12AB trusts.

Key Changes & Highlights

  • The separate regime for 10(23C) and 12AB has been merged to eliminate dual-compliance and regulatory arbitrage.

Related Sections

Section 12AB

Frequently Asked Questions

What does Section 10(23C) of the Income Tax Act 1961 deal with?

Section 10(23C) (Income of Educational and Medical Institutions) Exempts income of universities, hospitals, and educational institutions existing solely for education/philanthropy and not for profit.

What is the new section number for Section 10(23C) under the Direct Tax Code 2025?

Section 10(23C) of the ITA 1961 maps to Section 12 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective from 1st April 2026.

What is the status of Section 10(23C) under the new tax code?

Section 10(23C) is marked as "Retained" with status "Modified". Impact: High - Massively simplifies compliance for schools and hospitals.

What are the key changes to Section 10(23C) under DTC 2025?

The separate regime for 10(23C) and 12AB has been merged to eliminate dual-compliance and regulatory arbitrage.

Disclaimer: This page is for educational and reference purposes only. Section mappings are based on publicly available drafts and circulars. Always consult a qualified Chartered Accountant before filing or making compliance decisions under the Direct Tax Code 2025.

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