Section 10(23BBA) exemption is confined to a statutory body's own income, not temple or endowment income.

Section 10(23BBA) exempts only the income of a body or authority established, constituted or appointed under an enactment to administer public religious or charitable trusts or endowments; it does not extend to the income of the trust, endowment or temple itself. Under the Madras Hindu Religious and Charitable Endowments Act, temple properties and their income belong to the deity or temple, while the statutory body acts only as manager. The exemption may be available to the statutory body's own income if the statutory conditions are met, and the separate exemption framework in Sections 11, 12 and 12A supports this construction.

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Issues: Whether the exemption under Section 10(23BBA) of the Income-tax Act, 1961 applies to the income of temples and religious endowments administered by statutory bodies, or only to the income of the bodies or authorities constituted under the relevant enactment.

Analysis: Section 10(23BBA) exempts only the income of a body or authority established, constituted or appointed under a Central, State or Provincial Act for administering public religious or charitable trusts or endowments. The proviso clarifies that the income of the trust, endowment or society itself is not exempt. The scheme of the Madras Hindu Religious and Charitable Endowments Act, 1951 shows that the temple properties and resulting income belong to the deity or the temple, while the administrative body functions only as the manager. The exemption under Section 10(23BBA) is therefore confined to the statutory body's own income and does not extend to the income of the temple or endowment merely because it is administered by such body. The availability of exemption under Sections 11, 12 and 12A of the Income-tax Act, 1961 for religious and charitable institutions reinforces this construction.

Conclusion: The exemption under Section 10(23BBA) is not available to the income of temples or religious endowments administered by statutory bodies, though the statutory body itself may claim the exemption if its own income and the statutory conditions are established.

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