Form 112, Form 113: Charitable Trusts' Guide to Income Tax Rules 2026
The Income-tax Act 2025 and Income-tax Rules 2026 have renumbered all compliance forms for charitable trusts, NGOs, and exempt institutions. Form 112 now consolidates audit reporting, Form 113 replaces donor statements, and Section 332 replaces Section 12AB. Understand the new requirements, deadlines, and penalties for AY 2026-27 filing.
CA Harun Raaj
Chartered Accountant · Harun Raaj & Associates
Legal basis: Income-tax Act, 2025 (Section 332, 348, 354) and Income-tax Rules, 2026 (Rule 187) — Effective: 1 April 2026. Source: incometax.gov.in. Last reviewed by CA Harun Raaj: January 2026.
The Income-tax Act 2025 replaced the Income-tax Act 1961 with effect from 1 April 2026. Along with it came the Income-tax Rules 2026, which have renumbered virtually every compliance) form that charitable trusts, NGOs, Section 8 companies, and exempt institutions use. If your trust holds registration under Section 12AB (now Section 332), or approval under Section 80G) (now Section 354) or Section 10(23C), you need to understand what changed—and you need to act before your audit and return filing deadlines.
Section Numbers Renamed Across the Board
Under the Income-tax Act 2025, the sections governing charitable trusts and exempt institutions are renumbered:
- Section 12A / 12AA / 12AB → Section 332 (registration of trusts and charitable institutions, Part B of Chapter XVII, ITA 2025)
- Section 80G → Section 354 (deduction to donors)
- Audit requirement → Section 348 (ITA 2025), with Form 112 as the prescribed audit report
- Procedural requirements prescribed under Rule 187, Income-tax Rules 2026
This is not merely cosmetic renumbering. Your trust's legal status depends on compliance under the new section numbers, and all future applications, renewals, and amendments must reference Section 332, not Section 12AB.
Compliance Forms: Complete Renumbering Under Income-tax Rules 2026
The Income-tax Rules 2026 have renumbered the entire suite of forms used by registered trusts and NPOs. Below is the exact mapping:
Key point: All forms filed from 1 April 2026 onwards must use the new form numbers; the old forms are no longer accepted by the Income Tax Department.
Form 112: The End of the ₹5 Crore Bifurcation
Under the Income-tax Act 1961, determining which audit form to file was a source of routine errors and disputes:
- Form 10B—for trusts with receipts exceeding ₹5 crore, or with foreign contribution, or multiple objects
- Form 10BB—for all other auditable trusts
Under IT Rules 2026, Form 112 consolidates both into a single audit report for all NPOs registered under Section 332 or Section 10(23C), regardless of receipt threshold. The ₹5 crore bifurcation is eliminated. This simplifies compliance for larger trusts and removes a major source of procedural error.
Illustrative example: The Jain Educational Trust (receipts ₹7.5 crore, previously Form 10B) and the Mehta Charitable Foundation (receipts ₹80 lakh, previously Form 10BB) now both file Form 112. One form, one set of instructions.
ITR-7 Filing for AY 2026-27: Deadlines Are Live
The Income Tax Department released the Excel Utility for ITR-7 (AY 2026-27) on 9 July 2026 on the e-filing portal. Charitable trusts, Section 8 companies, educational institutions, hospitals, and political parties filing under Sections 139(4A), (4B), (4C), or (4D) can now download and prepare their returns.
Due dates for AY 2026-27 (ITR-7):
- Non-audit trusts (small trusts not required to get accounts audited): 31 July 2026 — no extension announced
- Audit trusts (majority of Section 332 registered entities): 31 October 2026
Note: The extended due date of 31 August 2026 for ITR-3 and ITR-4 (Finance Act 2026 staggered schedule) does not apply to ITR-7 filers. Charitable trusts file on their own calendar.
Form 113: Donor Statement Deadline Already Passed for FY 2025-26
Form 113 (formerly Form 10BD) is the annual statement of donations filed by the donee institution. For financial year 2025-26, the deadline was 31 May 2026. If your trust has not filed Form 113 for FY 2025-26, you are already in default.
Consequences:
- Penalty of ₹200 per day of default under Section 234G, ITA 1961
- Risk of denial or cancellation of registration under Section 332 if repeated defaults occur
File Form 113 for FY 2025-26 immediately to minimise penalty exposure.
Section 11(2) Accumulation: Application Before ITR Due Date
If your trust cannot apply 85% of its income to charitable purposes in the current year, you may accumulate income for up to 5 years under Section 11(2)—but only if you file the accumulation application before your ITR-7 due date.
- For non-audit trusts: File by 31 July 2026
- For audit trusts: File by 31 October 2026
Under IT Rules 2026, the accumulation statement is filed as Form 109. Missing this deadline means the accumulated amount loses Section 11(2) protection and becomes fully taxable in the year it would have been accumulated. This is a common compliance failure and results in significant and avoidable tax liability.
Consequences of Non-Compliance
- Wrong or missing audit form (Form 112): Risk of denial of exemption under Section 332(1)(b)
- Missing accumulation application (Form 109): Accumulated amount taxed at maximum marginal rate
- Late or missing Form 113 (donor statement): Penalty of ₹200 per day under Section 234G
- Repeated non-compliance: Cancellation of registration under Section 332
- Anonymous donations exceeding ₹1 lakh or 5% of total donations: Taxable at 30% under Section 115BBC
I'm CA Harun Raaj, Visakhapatnam. If your trust is facing Form 112, Form 113, or Section 332 compliance questions for AY 2026-27, reach out and we'll walk through your obligations step by step.
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See Also
Frequently Asked Questions
My trust was registered under Section 12AB in 2022 for five years. Does the Income-tax Act 2025 affect my existing registration?+
Your registration remains valid until its stated expiry date. At renewal, you will apply using Form 105 (replacing Form 10AB) under Section 332, ITA 2025. The five-year validity for regular registrations continues under the new Act. However, all compliance filings from 1 April 2026 onwards must reference Section 332 and use the new form numbers.
Is Form 112 required for AY 2026-27, or does Form 10B/10BB still apply?+
Form 112 is the prescribed audit report under IT Rules 2026 for AY 2026-27 and all subsequent years. Forms 10B and 10BB are no longer accepted. The Income Tax Department released the ITR-7 utility on 9 July 2026 with Form 112 embedded as the consolidated audit template.
Our trust has already missed the 31 May 2026 deadline for Form 10BD (now Form 113). What happens now?+
You are in default and face a penalty of ₹200 per day under Section 234G. File Form 113 immediately to stop the penalty clock. If you have not filed by now, the accumulated penalty can be substantial. Consult your CA to evaluate possible relief under Section 234G(4) and file the form without further delay.
Can our Section 8 company file ITR-8 instead of ITR-7?+
No. Section 8 companies registered under Section 332 (or holding Section 10(23C) exemption) must file ITR-7 under Section 139(4C), not ITR-8. Section 8 companies without exemption file ITR-1 or ITR-4 depending on their tax status. If you hold 12AB registration, ITR-7 is mandatory.
What is the deadline for Form 109 (accumulation statement) filing if our trust is subject to audit?+
Form 109 must be filed before your ITR-7 due date. For audit trusts, this is 31 October 2026 for AY 2026-27. Filing after this date means the accumulated income loses Section 11(2) protection and becomes fully taxable. Do not delay this application.
We have foreign contributions. Do we still use Form 112, or is there a separate form?+
You use Form 112 (consolidated audit report) regardless of whether you receive foreign contributions. Foreign contributions do not alter the audit form requirement. However, you must comply with FCRA registration and reporting requirements separately. Form 112 is the income-tax audit report only.
Does the ₹5 crore receipt threshold still apply to determine which audit form to file?+
No. The ₹5 crore bifurcation between Form 10B and Form 10BB has been eliminated under IT Rules 2026. All registered trusts and NPOs file Form 112 as their consolidated audit report, regardless of receipt level or size. This applies to AY 2026-27 and onwards.
If we do not get our accounts audited (non-audit trust), do we still need to file Form 112?+
No. Non-audit trusts file ITR-7 directly by 31 July 2026 without Form 112. Form 112 is required only for trusts that fall within the audit threshold under Section 348 (formerly Section 12AB(6)). Verify your audit eligibility from the trust deed and income level.
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