New Income Tax Act 2025 and Income Tax Rules 2026 for nonprofits for understanding and orientation of the new tax law | Part 3 of 15

Part 2 of 15

As we saw yesterday, the income tax provisions for charitable institutions have been structured in 7 neatly organised sub parts in Income Tax Act 2025. Let us do sub part 1 today. This sub part is regarding Registration of charitable institution for income tax exemption. But before that let us see some definitions

Please note that if you are registered as an exempt entity under income tax you will be called as ‘Registered Non Profit Organization (RNPO)’ from 1.4.2026. The Income Tax Act will call you as RNPO only always henceforth. Remember this acronym. But what is a Registered Non Profit Organization (RNPO)?

The Act defines “Registered non-profit organization” as any person having a valid registration under any specified provision and such registration has not been cancelled

So, if you are person with valid registration under any specified provisions of Income Tax Act 1961 or 2025 and it has not been cancelled, your organisation is an RNPO. If the NGO has valid registration no action is required at this stage.

Two more definitions

Charitable Purpose” Section 2(23) of Income Tax Act defines it to include–

  • Relief of the poor;
  • education;
  • yoga;
  • medical relief;
  • preservation of environment (including watersheds, forests and wildlife);
  • preservation of monuments or places or objects of artistic or historic interest;
  • the advancement of any other object of general public utility;

The proviso to limb g above has been removed whereas the definition is same as Section 2(15) of Income Tax Act 1961. Religious purpose has not been defined as was in ITA 1961

Tax Year means twelve months period of the financial year commencing on 1st April of such financial year

The Department has done away with Previous Year (PY) and Assessment Year (AY) completely from 1.4.2026 which used to confuse us so much.

Now let us do sub part 1 of Chapter XVII-B which deals with Registration

Registration (Sections 332-333) of Income Tax Act 2025

Section 332-Application for Registration- following persons (called registered non-profit organization) for claiming benefits under this Part, make an application for registration to P/CIT-

a. a public trust;

b. a society registered under the Societies Registration Act, 1860, or under any law in force

c. a company registered under section 8/25 of the Companies Act, 2013/1956

d. a University/ educational institution affiliated thereto or recognized by Govt

e. an institution financed wholly/partly by Government/local authority;

f. any person as referred to in

Schedule III-Income not to be included in total income of eligible persons (Table: Sl. No. 27) to (Table: Sl. No. 29) i.e. contribution to IPF setup by SE, CE and Depository and (Table: Sl. No. 36) i.e. section 10(46) i.e. entities created by central/state govt and notified by central govt for benefit of general public other than Sch VII Table sl 42 and

Schedule VII Persons exempt from Tax (Table: Sl. No. 10-16) PMNRF, PMCARES, SBM ,Clean Ganga, CM Relief Fund etc-deleted in Budget 2026, Table Sl 17-any University/edu institution substantially/wholly financed by Govt, Table Sl 18- any medical institution wholly/substantially financed by Govt and Table, Sl 19-any educational or medical institution with gross receipts upto Rs. 5 cr.PA, Table: Sl. No. 42-any body/authority setup by Central/State Act for housing, development of cities, village, regulating activity for benefit of general public; or

g. any other person notified by CBDT

Below are types of registration/approval for RNPO under ITA 2025

Table- 332-cases, time limit for application, approval by Dept and validity of registration

Sl. No. Case Time limit for furnishing application Time limit for passing order Validity of registration
1 Where the activities of the applicant have not commenced and it has not been registered under any specified provision at any time before making the application. At any time during the tax year beginning from which registration is sought. One month from the end of the month in which application is made. Three tax years commencing from the tax year in which such application is made.
2 Where the activities of the applicant have commenced and it has not been registered under any specified provision at any time before making the application. At any time during the tax year, beginning from which registration is sought. Six months from the end of the quarter in which application is made. Five tax years commencing from the tax year in which such application is made.
3 Where the applicant has been granted provisional registration and activities have commenced. Within six months of the commencement of activities. Six months from the end of the quarter in which application is made. Five tax years commencing from the tax year in which such application is made.
4 Where the provisional registration of the applicant is due to expire and activities have not commenced. At least six months prior to the expiry of the provisional registration. Six months from the end of the quarter in which application is made. Five tax years following the tax year in which such application is made.
5 Where the registration of the applicant is due to expire, other than cases mentioned at serial number 4. At least six months prior to the expiry of the registration. Six months from the end of the quarter in which application is made. Five tax years following the tax year in which such application is made.
6 Where the registration of the applicant has become inoperative due to switching over of regime under Section 333 At any time during the tax year beginning from which the registration is sought to be made operative. Six months from the end of the quarter in which application is made. Five tax years commencing from the tax year in which such application is made.
7 Where the applicant, being a registered NPO has adopted or undertaken modification of its objects which do not conform to the conditions of registration. Within thirty days of the date of such adoption or modification Six months from the end of the quarter in which application is made. Five tax years commencing from commencement of the tax year in which such application is made.

So, all possible cases of registration/approval/renewal etc will fall in one or the other serial no in above table.

Conditions for registration

  1. Person must be constituted/registered/incorporated for charitable purpose under (2(23) or public religious purposes
  2. Properties held under an irrevocable trust for benefit of public wholly for charitable/religious purpose
  • Condonation for delay in filing registration application by P/CIT with reasonable cause for delay in registration application
  • Accreted tax if condonation is not granted in cases for Table sl. No 3,4,5,7 (3. conversion of provisional regn, 4. renewal of provisional 5. renewal of regular regn and 7. modification of objects)
  • If income in past 2 tax years prior to application is upto Rs. 5 cr, registration granted for 10 years-applicable to cases in Table sl. 3 to 7
  • For cases in Table sl. No. 2-7, P/CIT see gaminess and compliance with other laws and grant/reject registration (after giving opportunity of being heard in case of rejection)
  • Provisional registration granted by P/CIT only

The above are provisions relating to Registration of RNPO. Please raise your queries on today’s post on Forum.

Tommorow, we will understand the provisions of sub part 2 of Chapter VII-B i.e. Income of RNPO.

See you tomorrow.

CS Sharad Bhargava

Part 3 of Part 15

Welcome to Part 3 of our orientation on Income Tax Act 2025 for Registered Non-Profit Organisations (RNPO).

Today, we will share sub part 3 of Chapter XVIII-B of Income Tax Act 2025. Remember the title of this Chapter is “Special Provisions for Registered NPOs” and that we are called Registered Non-Profit Organisation as per Income Tax Act from 1st April.

Sub Part 3 of Chapter XVII-B-Income of registered NPO-Sections 334-343

This sub part deals with Income and Application of RNPOs and is the biggest sub part in the Chapter. It includes all matters relating to income, application and accumulation of income of an RNPO.

Section 334-Tax on income of RNPO-Income tax on total income for a tax year will be (a) @30% on specified income (a) at the rate applicable on taxable regular income

This section tells an RNPO like us that tax will be @30% if the income is categorized as Specified Income as per Section 337 and at slab rates for income left after applying 85% application rule.

Section 335-Regular income includes-(a) receipts from charitable or religious activity for which registered (b) capital/revenue receipts from property/investment held (c) voluntary contribution (d) gains from commercial activity received in tax yea r

This section tells an RNPO that income tax law recognizes 4 types of income, and the law now specifies receipts from charitable/religious activity for which RNPO is registered which was not explicit in the erstwhile Income Tax Act 1961. This means that if you are an educational institution, the tuition fees is receipts from charitable activity of education which you must have selected while filing Form 10A or 10AB for registration or renewal for tax exemption .

Section 336-Taxable regular income is (a) nil if 85% or more of income in tax year applied or accumulated as per 342 (b) 85% regular income less application and accumulat ion

This section tells an RNPO that if 85% or more of the income is applied, there is nil tax but tax on regular income at slab rates will apply if the 85% rule both in terms of application and accumulation is not fulfill ed.

Section 337-Specififed income-taxable in same tax year (except h where it is last year)

(a) Anonymous donation (excludes religious/charitable cum religious except for an educational/medical institution)-Rs.1 lakh or 5% of donations whichever is higher

(b) Income applied for benefit of a related person

(c) Income applied outside India in contravention of Sectio n 338(a)

(d) Investment of any income, deemed accumulated income, accumulated income, corpus, deemed corpus or any other fund in violation of 350

(e) Deemed corpus donation for violation of conditions in 340 (donation for repair of religio us places)

(f) Accumulated income applied for purpose other than for which accumulated

(g) Accumulated income ceases to be accumulated (conditions not fulfilled)

(h) Accumulated income not applied within prescribed period-342(1)

(i) Accumulated income paid to another registered NPO

(j) Income applied for other than charitable or religious purpose for which registered

(k) Income determined by AO more than income as shown for business undertaking

(l) Fair market value of asset not held in modes under Schedule XVI after expiry of 1 year from end of tax year in which acquired

(m) Deemed application not applied within allowed timeline

This section tells an RNPO situations in which income received or applied will attract 30% taxation due to the relevant violations. What is very important is that an RNPO like you must recognise that your do not fall under any of the situations i.e.a-m above otherwise the income received or utilised will be taxed at 30% flat and not at slab rate.

Section 338-Income not to be included in regular income-

(a) income applied outside India approved by CBDT to promote international welfare in which India is interested and

(b) corpus donation received by RNPO

This section tells an RNPO that two types of income will not form part of regular income, one, when income is applied outside India with CBDT approval and CBDT will approve if income is applied to promote international welfare in which India is interested which is a new addition in the Act. Second, corpus donation as we know is a capital receipt and is not included in income provided it fulfils all conditions required to be considered corpus.

Section 339-Corpus donation-donation made with specific direction by donor to treat as corpus and invested in permitted modes of investment under section 350

This section tells the RNPO the definition of corpus which is the same definition as in the erst while Income Tax Act 961

Section 340-Deemed corpus donation-donation for repair of temple, gurudwara, church, mosque etc is deemed corpus donation provided conditions are fulfilled i.e. Separately identified, invested as per Section 350 which we will study, used for repair work for which received and not given a s donation to any person.

This section is meant for religious institutions receiving donations for repair work of religious institutions. Such donations will be deemed as corpus donation because repair woks are long terms and the section provides relief from applying 85% of receipts during the same year which is a challenge for religious institutions. The case to point to is Ram Janam Bhumi temple which receives huge donations which cannot be applied to the exten t of 85% in the same year.

Our Part 4 in the series on coming Monday will continue with our discussion on sub part 3 of Chapter VII-B which will cover two aspects i.e. Application of Income and Accumulation of Income if not applied to the extent of 85% of income under

Please post your queries on Forum regarding the provisions and the series. Have a nice weekend.

CS Sharad Bhargava