Finance/Compliance Consultant
77999 Points
Posted on 06 November 2026
Yes, with conditions for the donor trust (Sec 11/12 registered):
• Donation to another trust or institution registered under Sec 12AB / 10(23C), not towards corpus: counts as application of income for the donor. From AY 2024-25 (Finance Act 2023), only 85% of such donation is treated as application (Explanation 4 to Sec 11(1)). The remaining 15% is effectively unapplied.
• Donation towards the corpus of another trust: not application (Explanation 2 to Sec 11(1)), so the donor has to apply that amount again.
• Donee must be registered. A donation to an unregistered entity is not application, and may violate the donor's objects.
• For the receiving NGO:
– a non-corpus donation is income (voluntary contribution, Sec 2(24)(iia)), to be applied
– a corpus donation with specific direction is exempt (Sec 11(1)(d)), subject to the investment rules.
• FCRA: if the donor NGO has FCRA funds, it cannot transfer foreign contribution to any other person or entity (Sec 7 FCRA, as amended 2020). Domestic funds only.
• No Sec 80G deduction for the donor trust (it is exempt anyway). The donee issues a receipt; Form 10BD applies only to donations eligible under 80G.