Circular No. 12/2002

1073. Exemption from requirement of deduction of income-tax at source on payment to Sri Sathya Sai Central Trust, Sri Sathya Sai Medical Trust and Sri Sathya Sai Institute of Higher Learning, Bangalore, whose incomes are exempt under section 10(23C) of the Income-tax Act, 1961

What this is

Circular No. 12/2002 was issued by the Central Board of Direct Taxes on 22 November 2002. Its subject is 1073. Exemption from requirement of deduction of income-tax at source on payment to Sri Sathya Sai Central Trust, Sri Sathya Sai Medical Trust and Sri Sathya Sai Institute of Higher Learning, Bangalore, whose incomes are exempt under section 10(23C) of the Income-tax Act, 1961.

This grants an exemption or a relief under a provision that allows one. Read the conditions attached: an exemption notification is construed strictly, and a condition missed is the exemption lost.

What it does

Allows three named institutions to be paid certain incomes without deduction of tax at source. Interest other than interest on securities, rent, and income in respect of units of a mutual fund specified under section 10(23D) or of the Unit Trust of India may be paid to Sri Sathya Sai Central Trust, Sri Sathya Sai Medical Trust and Sri Sathya Sai Institute of Higher Learning, Bangalore without deduction under sections 194A, 194-I and 194K. The relief is stated to apply for the financial years 2002-03 and 2003-04, that is assessment years 2003-04 and 2004-05.

Why it was issued

The incomes of the three institutions were exempt for assessment years 2002-03 to 2004-05 under section 10(23C)(iv), (via) and (vi) respectively, so deduction at source on their receipts would only have generated refund claims. The Board examined the matter and granted the relief.

Who it reaches

Banks and companies paying interest to the three named Sathya Sai institutions
Tenants paying rent to those institutions
Mutual funds and the Unit Trust of India making unit payments to them
The three institutions themselves

The provisions it speaks to

Left, the provision of the Income-tax Act, 1961 as the instrument itself names it. Right, the section of the Income-tax Act, 2025 that the department’s own concordance maps it to — which is where the same ground is now covered.

Under the 1961 Act	Now
s.10	s.11, s.19
s.194A	s.2, s.393, s.400, s.402

The instrument, as the Board published it

The words below are the department’s own, reproduced from its published text. Where the department’s copy carried a publisher’s notes after the instrument, those are not reproduced.

1073. Exemption from requirement of deduction of income-tax at source on payment to Sri Sathya Sai Central Trust, Sri Sathya Sai Medical Trust and Sri Sathya Sai Institute of Higher Learning, Bangalore, whose incomes are exempt under section 10(23C) of the Income-tax Act, 1961
1. The matter regarding grant of exemption from deduction of income-tax at source under sections 194A, 194-I and 194K of the Income-tax Act on the payment of incomes to Shri Sathya Sai Central Trust, Sri Sathya Sai Medical Trust and Shri Sathya Sai Institute of Higher Learning, Bangalore, whose incomes are exempt for assessment years 2002-03 to 2004-05 under section 10(23C)( iv), 10(23C)( via) and 10(23C )(vi) of the Income-tax Act, 1961 respectively has been examined by the Board.
2. It has been decided by the Board that in the cases of Sri Sathya Sai Central Trust, Shri Sathya Sai Medical Trust and Shri Sathya Sai Institute of Higher Learning, Bangalore, the incomes by way of—
(i) interest other than ‘income by way of interest on securities’
(ii) rent, and
(iii) income in respect of units of a Mutual Fund specified under section 10(23D) or of the Unit Trust of India
may be paid to these Institutions without deduction of income-tax at source. The provisions of this Circular shall be applicable for the financial years 2002-03 and 2003-04 (assessment years 2003-04 and 2004-05).
Circular : No. 12/2002, dated 22-11-2002.

What to watch

The circular names three institutions only; it is no authority for any other trust, however similar.
It covers three heads of income only, and interest on securities is expressly outside it.
The circular fixes its own outer limit: it applies for the financial years 2002-03 and 2003-04 alone, both of which have long passed.
The relief rests on the section 10(23C) exemption those institutions held for assessment years 2002-03 to 2004-05; the circular says nothing about any later period.

Where you meet it

In a payer's defence to a section 201 demand for failure to deduct on rent or interest paid to these institutions in those two years.

On the same provision

Other instruments in this library that name the same provision of the 1961 Act. They are not necessarily still operative, and a later one may have replaced an earlier one without saying so.

Notification No. 116/2026 [F. No.195/13/2025-ITA-I] / SO 4706(E) : Notification in the case of Maharashtra Electricity Regulatory Commission — [भाग II—खण् ड 3(ii)] भारत का रािपत्र : असाधारण 3 25 August 2026
Notification No. 112/2026 [F. No. 300196/6/2026-ITA-I] / SO 4458(E) : Notification in the case of District Legal Service Authority, Panchkula — Ministry of Finance 11 August 2026
Notification No. 109/2026 [F. No. 300196/39/2025-ITA-I] / SO 4321(E) : Notification section 536 (1) of the Income Tax Act, 2025 (30 of 2025) in the case of Odisha Joint Entrance Examination Committee — [भाग II—खण् ड 3(ii)] भारत का रािपत्र : असाधारण 3 4 August 2026
Notification No. 107/2026 [F. No. 300196/65/2018-ITA-I] / SO 4319(E) : Notification section 536 (1) of the Income Tax Act, 2025 (30 of 2025) in the case of Noida Special Economic Zone Authority — [भाग II—खण् ड 3(ii)] भारत का रािपत्र : असाधारण 3 4 August 2026
Notification No. 106/2026 [F. No. 300196/65/2018-ITA-I] / SO 4318(E) : Notification section 536 (1) of the Income Tax Act, 2025 (30 of 2025) in the case of Noida Special Economic Zone Authority — [भाग II—खण् ड 3(ii)] भारत का रािपत्र : असाधारण 3 4 August 2026
Notification No. 104/2026 [F.No.300196/1/2026-ITA-I] / SO 4308(E) : Notification section 536 (1) of the Income Tax Act, 2025 (30 of 2025) in the case of District Legal Service Authority, Charkhi Dadri — Ministry of Finance 3 August 2026

← Circular No. 11/2002 · Circular No. 10/2002 →

A circular binds the department, not you and not a court. The Board issues a circular to its own officers. An assessee may hold the department to a circular that helps him; the department cannot hold an assessee to one that hurts him, and the Tribunal and the courts decide the law for themselves.

Source: the Income Tax Department’s own published text — its page for this instrument.