Notification u/s 47 of the Income Tax Act, 1961 r.w.s 536(2) of the Income Tax Act, 2025 for transfer of capital asset from Nuclear Power Corporation of India Limited (NPCIL), being transferor public sector company, to Anushakti Vidhyut Nigam Limited (ASHVINI)

**Executive Summary** This notification, issued by the Ministry of Finance on July 17, 2026, formalizes the transfer of capital assets from Nuclear Power Corporation of India Limited (NPCIL) to Anushakti Vidhyut Nigam Limited (ASHVINI). The transfer is executed under a Central Government-approved plan dated October 15, 2025, and is legally effective for Financial Year 2025-26 (Assessment Year 2026-27). The document confirms that the retrospective application of this notification does not adversely affect any person. **Key Points / Main Content** **Legal Authority and Scope** * The notification is issued under clause (viiaf) to section 47 of the Income-tax Act, 1961, read with section 536(2) of the Income-tax Act, 2025. * It specifically notifies the transfer of capital assets between two identified public sector companies. **Entities Involved** * **Transferor:** Nuclear Power Corporation of India Limited ('NPCIL'), a public sector company (PAN: AAACN3154F). * **Transferee:** Anushakti Vidhyut Nigam Limited ('ASHVINI'), a public sector company (PAN: AAJCA9421F). **Timeline and Applicability** * The transfer follows a plan approved by the Central Government on October 15, 2025. * The notification applies to the year of transfer, specifically Financial Year 2025-26 and Assessment Year 2026-27. **Retrospective Certification** * An explanatory memorandum certifies that providing retrospective effect (from the financial year of transfer) does not result in any adverse impact on any individual or entity. **Impact Analysis** **Nuclear Power Corporation of India Limited (NPCIL)** **Impact** Designated as the transferor public sector company for the capital asset transfer. The entity is now formally recognized under specific Income-tax Act clauses for this transaction. **Action Required** Ensure the transfer of capital assets is recorded and reported in compliance with the notified plan and tax requirements for Financial Year 2025-26. **Anushakti Vidhyut Nigam Limited (ASHVINI)** **Impact** Designated as the transferee public sector company receiving the capital assets. The transaction is validated for tax purposes under the approved government plan. **Action Required** Reflect the receipt of capital assets in financial and tax filings for Assessment Year 2026-27 in accordance with the notification. **Central Board of Direct Taxes (CBDT) / Tax Authorities** **Impact** The notification provides the legal basis for the tax treatment of the asset transfer between these two specific public sector entities for the 2025-26 period. **Action Required** Apply the provisions of this notification when assessing the tax liabilities and capital asset transfers of NPCIL and ASHVINI for the specified assessment year.

Key Entities Referenced