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ITA 1961 → ITA 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 Income-tax Act, 2025, effective 1st April 2026. Status: Retained.

What changed for Section 10(23C)

Under the Income Tax Act, 1961, Section 10(23C) governs income of educational and medical institutions. Exempts income of universities, hospitals, and educational institutions existing solely for education/philanthropy and not for profit.

From 1st April 2026, the same subject sits at Section 12 of the Income-tax Act, 2025 — retained and renumbered as Section 12 of the Income-tax Act, 2025. Retained but heavily regulated. Completely aligned with the registration and compliance framework of Section 12AB trusts.

For Section 10(23C), the practical impact is rated High. Massively simplifies compliance for schools and hospitals.

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 (ITA 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 is Section 10(23C) of the Income Tax Act, 1961 about?

Section 10(23C) of the Income Tax Act, 1961 covers income of educational and medical institutions. Exempts income of universities, hospitals, and educational institutions existing solely for education/philanthropy and not for profit.

Which section replaces Section 10(23C) in the Income-tax Act, 2025?

Section 10(23C) of the Income Tax Act, 1961 maps to Section 12 of the Income-tax Act, 2025, effective 1st April 2026 (status: Retained). Retained but heavily regulated. Completely aligned with the registration and compliance framework of Section 12AB trusts.

What is the impact of the change to Section 10(23C) under the new tax code?

The transition impact for Section 10(23C) is rated High. Massively simplifies compliance for schools and hospitals.

What should I watch out for when Section 10(23C) moves to the 2025 code?

The separate regime for 10(23C) and 12AB has been merged to eliminate dual-compliance and regulatory arbitrage. These points are specific to Section 10(23C) (Income of Educational and Medical Institutions).

Disclaimer: This mapping of Section 10(23C) (Income of Educational and Medical Institutions) to Section 12 of the Income-tax Act, 2025 is for educational and reference purposes only, based on publicly available drafts and circulars. As Section 10(23C) is currently marked Retained, always confirm its treatment with a qualified Chartered Accountant before filing or making compliance decisions.

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