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NGO & Trust

Charitable Trust and NGO Tax Compliance Under ITA 2025: 12AB, 80G & FCRA Guide

VS Vikas Sharma 📅 March 26, 2026 ⏱️ 3 min read 👁️ 0 views
Legal Reference
Section 135 (80G registration for donors), Section 136 (12AB registration for trust exemption), Section 206 MAT not applicable, 15% accumulation Form 9A, FCRA for foreign donations, ITA 2025

1. Charitable Trust and NGO: Tax Exemption Framework

Charitable trusts, registered societies, and Section 8 companies can obtain tax exemption under ITA 2025 — making their income from charitable activities exempt from income tax. There are two separate registrations required: 12AB registration (for the trust income to be exempt) and 80G registration (for donors to get deduction on their donations). Both are now obtained online through the IT Portal.

2. Section 136 (12AB): Trust Income Exemption

To claim exemption on trust income, the trust must obtain 12AB registration from the jurisdictional Principal Commissioner of Income Tax:

  • Form 10A: online application on IT Portal
  • Documents: trust deed/memorandum, PAN, objects of trust, list of trustees, bank accounts, audited financials
  • Provisional registration: granted for 3 years for new trusts — then must apply for final registration
  • Final registration: for 5 years (renewable); requires activity report and financials
  • Once registered: income "applied" for charitable purposes is exempt from tax
  • Accumulation: up to 15% of income can be accumulated without immediate application (Form 9A must be filed)

3. Section 135 (80G): Donor Deduction

80G registration allows donors to claim deduction on their donations. The trust must separately apply for 80G registration. The deduction available to donors depends on the category of the trust:

  • Approved trusts under 80G: 50% of donation with qualifying limit (10% of ATI)
  • Certain national funds: 100% without limit (PM-CARES, PMNRF etc.)
  • The trust must file Form 10BD (statement of donations received) and issue Form 10BE (donation certificate) to donors

4. What is Charitable Purpose?

Schedule VII of ITA 2025 (equivalent to Section 2(15) of ITA 1961) defines charitable purpose:

  • Relief of the poor
  • Education
  • Yoga
  • Medical relief
  • Preservation of environment (ecology, forests, wildlife)
  • Preservation of monuments of historic importance
  • Any other object of general public utility

"General public utility" is restricted: activities for the benefit of a specific community or group only (not general public) may not qualify. Commercial activities (even if incidental) above a threshold can disqualify the charitable purpose claim.

5. Compliance Requirements After Registration

RequirementFilingDue Date
Annual return of trustITR-731 October (audit cases)
Audit of accounts (if income > Rs 2.5L)Form 10B/10BB30 September
Statement of donations receivedForm 10BD31 May
Accumulation report (if accumulating >15%)Form 9A / Form 1031 October
Foreign contribution report (if FCRA registered)FC-431 December

6. FCRA: Foreign Contributions

Charitable trusts and NGOs receiving foreign donations must separately register under the Foreign Contribution (Regulation) Act (FCRA) with the Ministry of Home Affairs. FCRA registration is mandatory for any foreign donation — without it, the foreign contribution is illegal. FCRA-registered organisations must maintain a designated bank account (State Bank of India, New Delhi Main Branch), file annual FC-4 returns, and use foreign contributions only for declared purposes.

7. Corpus Donations

Donations specifically made to the corpus of the trust (with donor intent to build the permanent corpus) are treated differently — they are not "income applied" but additions to corpus. Corpus donations are exempt and not included in "income" for the year. This allows large capital donations to be accepted without disturbing the income-application ratio.

8. Common Compliance Pitfalls

  • Not filing Form 10BD: donors cannot claim 80G deduction even if the trust has valid registration
  • Religious activities beyond permissible limits: reduces charitable purpose claim
  • Accumulation beyond 15% without proper Form 9A: entire accumulated income becomes taxable
  • Delayed 12AB renewal: exemption lapses; income becomes taxable
  • Accepting foreign donation without FCRA: illegal; trust/trustees liable for prosecution

9. Why TaxClue

Trust and NGO compliance — 12AB/80G registration, ITR-7, Form 10BD, FCRA — is highly specialised. TaxClue assists with registration, annual compliance, and donor certificate issuance. Contact us for NGO/trust advisory under ITA 2025.

Disclaimer
This article is for general informational and educational purposes only. It does not constitute legal, financial, or professional tax advice. Readers are advised to consult a qualified Chartered Accountant or tax professional before making any decisions. TaxClue Consultech Pvt Ltd accepts no liability. All case studies and examples in this article are illustrative only and do not represent actual persons or transactions.

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❓ Frequently Asked Questions
How does a charitable trust get tax exemption?
A charitable trust must obtain 12AB registration under Section 136 of ITA 2025 from the jurisdictional Principal Commissioner. Apply online using Form 10A on the IT Portal with trust deed, PAN, list of trustees, bank accounts, and audited financials. New trusts get provisional registration (3 years); established trusts get final registration (5 years, renewable). Once registered, income applied for charitable purposes is exempt from income tax.
What is 80G registration for a trust?
80G registration under Section 135 of ITA 2025 allows donors to the trust to claim deduction on their donations. The trust applies separately for 80G. Registered trusts must file Form 10BD (list of donations received) by 31 May and issue Form 10BE (donation certificates) to donors. Without Form 10BD filing, donors cannot claim 80G deduction in their ITR — even if the trust has valid 80G registration.
How much income can a trust accumulate without paying tax?
A 12AB registered charitable trust can accumulate up to 15% of income in any year without applying it immediately to charitable purposes. For accumulation beyond 15%, Form 9A must be filed (specifying the purpose and time period for using the accumulated amount — up to 5 years) and Form 10 must be filed with the ITR. Accumulation without filing these forms makes the entire accumulated income taxable for that year.
What is FCRA registration?
FCRA (Foreign Contribution Regulation Act) registration from the Ministry of Home Affairs is mandatory for any NGO or charitable trust that wishes to receive foreign donations (funds from foreign nationals, foreign organisations, or foreign governments). Without FCRA registration, accepting foreign contributions is illegal and can result in prosecution. FCRA organisations must maintain a designated SBI New Delhi branch account, file annual FC-4 returns by 31 December, and use foreign funds only for declared purposes.
What are the annual compliance requirements for a trust?
Annual compliance for a 12AB registered trust: file ITR-7 (by 31 October for audit cases); get accounts audited (Form 10B/10BB) by 30 September if income exceeds Rs 2.5L; file Form 10BD (list of donations) by 31 May; issue Form 10BE certificates to donors; file Form 9A (if accumulating income beyond 15%); renew 12AB registration every 5 years; renew 80G registration periodically. FCRA organisations additionally file FC-4 by 31 December.

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