Should a Trust Deed Executed After April 2026 Refer to the Income Tax Act, 1961 or Income Tax Act, 2025?

Hello @Sharad Sir, I am currently drafting a Trust Deed for a non-profit organization and would appreciate your guidance regarding the Income Tax provisions that should be referred to in the deed.

Specifically, I would like to know whether we should continue referring to the provisions of the Income Tax Act, 1961 or whether references should now be updated to the Income Tax Act, 2025, particularly for the following clauses:

1. Investment Clause

Example:

“The funds of the Trust shall be invested or deposited only in the modes specified under Section 11(5) read with Section 13(1)(d) of the Income Tax Act, 1961, as amended from time to time.”

2. Irrevocability / Amendment to the Trust Clause

Example:

“No amendment to this Trust Deed shall be made which is inconsistent with or repugnant to the provisions of Sections 2(15), 11, 12, 13 and 80G of the Income Tax Act, 1961, as amended from time to time.”

Could you please review these clauses and advise which Act and corresponding provisions should be referred to in a trust deed being executed after April 2026?

Additionally, if you have any sample trust deed or updated drafting precedents prepared after April 2026 that incorporate the new Income Tax law provisions, I would be grateful if you could share them.

Thank you for your guidance and assistance.

Thanks Goutham for your query. You will have to refer to Income Tax Act 2025 only for a trust deed registered after 1.4.2026. We are attaching a section navigator from ITA 1961 to ITA 2025 which will help you locate the new sections to be used. For example Section 11(5) and 13(1)(d) is now Section 350. Section 2(15) is 2(23) and 11,12,13 maybe replaced with Sections 332-355 of Chapter XVII-B of ITA 2025.

We do not have a ready template but besides standard clauses, please include clause on Books of Accounts & Audit (Section 347,348), Dissolution and transfer of assets to another RNPO (Section 352 Table sl. 9), Irrevocability (Section 332(2)(b)), no commercial activity (Section 345), Income and Application of Income (Sections 334-343).

You would need to know the Sections containing provisions for an RNPO under ITA 2025 effective 1st April.

Hope it helps.

CS Sharad Bhargava

new-income-tax-Act-2025-navigator.pdf (757.3 KB)

Thank you so much @Sharad Sir. This is really helpful!