Section 115BBC Anonymous Donations and Section 115BBD Foreign Dividends

Section 115BBC dealt with taxation of anonymous donations received by specified charitable, religious, educational and medical entities. Section 115BBD provided a concessional tax regime for certain dividends received by an Indian company from a specified foreign company. Their present relevance is different and should be read with the Income-tax Act, 2025, which came into force on 1 April 2026.

Updated: 28 September 2026

Current-law note: The Income-tax Act, 2025 is now the operative statute from 1 April 2026. For the current regime, anonymous donations of registered non-profit organisations are addressed through Sections 334 and 337 of the 2025 Act. Section 115BBC remains important for matters governed by the Income-tax Act, 1961, subject to applicable repeal and savings provisions.

Provision	What it covered	Present position
Section 115BBC, Income-tax Act, 1961	Anonymous donations received by specified exempt entities.	Historical 1961 Act provision. The current 2025 Act addresses the corresponding treatment principally in Sections 334 and 337.
Section 115BBD, Income-tax Act, 1961	15% tax on qualifying dividends received by an Indian company from a specified foreign company.	Does not apply to any assessment year beginning on or after 1 April 2023. It remains relevant to applicable earlier years and related proceedings.

Anonymous donations: meaning and current tax treatment

Under the earlier Section 115BBC, an anonymous donation was a voluntary contribution for which the recipient did not maintain the prescribed record of the donor's identity, including the donor's name and address and other prescribed particulars.

For tax years governed by the Income-tax Act, 2025, Section 337 treats qualifying anonymous donations of a registered non-profit organisation as specified income. Section 334 taxes specified income at 30%.

Threshold for anonymous donations

The special anonymous-donation amount is determined after excluding the higher of:

Rs. 1,00,000; or
5% of the total donations received during the tax year.

Religious and charitable organisations

The current rule excludes a registered non-profit organisation established wholly for religious purposes. It also contains an exclusion for an organisation established wholly for charitable and religious purposes, subject to the exception for an anonymous donation specifically directed to a university, educational institution, hospital or other medical institution run by that organisation.

Record keeping

Organisations receiving voluntary contributions should maintain donor-identification records and the particulars required by the applicable law and forms. The 2026 return framework separately identifies anonymous donations falling within the special tax rule.

Section 115BBC of the Income-tax Act, 1961

For periods and proceedings to which the Income-tax Act, 1961 continues to be relevant, Section 115BBC imposed tax at 30% on aggregate anonymous donations exceeding the higher of 5% of total donations or Rs. 1,00,000. The balance of the assessee's income was taxed under the otherwise applicable provisions.

The provision applied to specified entities, including covered universities, educational institutions, hospitals, funds, trusts and institutions referred to in Section 10(23C), and trusts or institutions referred to in Section 11. It excluded donations received by wholly religious trusts or institutions and provided the limited religious-cum-charitable exception described above.

Transition: For a current tax-year question under the Income-tax Act, 2025, the corresponding 2025 Act provisions should be checked first. For an earlier assessment year, pending proceeding, appeal or other saved matter, the 1961 Act may still require examination.

Section 115BBD: dividends from specified foreign companies

Section 115BBD historically applied where an Indian company's total income included dividends declared, distributed or paid by a specified foreign company. A specified foreign company meant a foreign company in which the Indian company held 26% or more of the nominal value of its equity share capital.

When applicable, the provision taxed the qualifying dividend income at 15%, while the remaining total income was taxed under the otherwise applicable provisions. No deduction for expenditure or allowance was permitted in computing the dividend income covered by the section.

Important: Section 115BBD(4), inserted by the Finance Act, 2022 with effect from 1 April 2023, provides that Section 115BBD does not apply to any assessment year beginning on or after 1 April 2023. The 15% rate is therefore not a current concessional rate for present assessment years.

Meaning of dividend under the historical provision

For Section 115BBD, "dividend" had the meaning assigned under Section 2(22) of the Income-tax Act, 1961, but excluded the item covered by Section 2(22)(e).

Key takeaways

The Income-tax Act, 2025 came into force on 1 April 2026 and is the starting point for current tax-year analysis.
The present anonymous-donation regime for registered non-profit organisations is principally contained in Sections 334 and 337 of the 2025 Act.
Specified income under Section 337 is taxed at 30% under Section 334.
The anonymous-donation threshold retains the higher of Rs. 1,00,000 or 5% of total donations.
Section 115BBD's 15% foreign-dividend regime does not apply from assessment year 2023-24 onward.
Earlier-year disputes and saved proceedings may still require reference to Sections 115BBC and 115BBD of the 1961 Act.

This article is a general legal and tax reference. Applicability can depend on the relevant tax year, entity status, registration, nature of receipts and transition provisions.