The Central Board of Direct Taxes (CBDT) has redesigned the provisional registration form for non-profit organisations under the new Income-tax Act, 2025, cutting data points, automating filing, and making compliance faster and easier than ever before.
An Overview of Revamped Form 10A
As part of the "Taxpayer Information Series," the Income Tax Department has introduced a sweeping set of simplified tax forms under the Income-tax Act, 2025, which takes effect from April 1, 2026. The new forms leverage simpler language, standardised pre-filled formats, and technology-driven processes to reduce errors and facilitate compliance.
At the centre of this reform is Form No. 104, previously known as Form No. 10A. This is the common application form used by non-profit organisations (NPOs) seeking provisional registration or approval under Section 332 of the Income-tax Act, 2025.
Purpose of Form No. 104
Form No. 104 is a common application form for the following entities:
- Any non-profit organisation seeking provisional registration under Section 332(3) (Table: Sl. No. 1) of the Income-tax Act, 2025, for claiming benefits applicable to registered non-profit organisations.
- Any registered non-profit organisation or regimental fund or non-public fund established by the armed forces of the Union (Schedule VII, Table: Sl. No. 1), seeking provisional approval so that donations become eligible for deduction under Section 133(1)(b)(ii) of the Income-tax Act, 2025.
Who Should File Form No. 104?
The form is required to be filed by the following two categories of applicants:
Category 1: New NPOs Seeking Registration
Any non-profit organisation referred to in Section 332(1) of the Income-tax Act, 2025, whose activities have not yet commenced and which was not previously registered under Section 332 or Section 12A, 12AA, 12AB, or 10(23C) of the Income-tax Act, 1961, applying to avail benefits under the Act, subject to provisional registration or incorporation in India for charitable or religious purposes and holding property for the benefit of the general public under an irrevocable trust.
Category 2: NPOs Seeking Provisional Approval (Section 354(2))
Any registered non-profit organisation, regimental fund, or non-public fund of the Union armed forces (Schedule VII, Sl. No. 1), whose activities have not yet commenced, applying for provisional approval under Section 354(2) so that donations received become eligible for deduction under Section 133(1)(b)(ii) of the Income-tax Act, 2025.
Structure of New Form No. 104: As Per Income Tax Rules, 2026
The revamped Form No. 104 is structured into the following parts:
| Sl. No. | Structure of Form No. 104 | Summary of Information Required |
|---|---|---|
| 1 | Part A - Personal Information | Name, PAN and address of the applicant |
| 2 | Part B - Other Information | General and regulatory information |
| 3 | Opening Qualifying Questions | Whether established under an instrument and whether the trust deed is irrevocable; whether any past application for registration/approval was rejected; whether public religious expenditure exceeds 5% of total income in any tax year |
| 4 | Details of Incorporation / Constitution | Type of application (provisional/regular/both), nature of applicant, nature of activities, incorporation details and objects |
| 5 | Details of Existing Registration / Approval | Existing registrations under Income-tax Act, 1961 / Income-tax Act, 2025 or any other law |
| 6 | Details of Office Bearers | Name, relationship with applicant, shareholding (>5%), unique ID, address, mobile number and email |
| 7 | Beneficial Ownership Details | Details of ultimate beneficial owner where office bearer is not an individual (name, ID, address, % ownership) |
| 8 | Return of Income Filing Status | Whether return of income was filed for the last tax year |
Documents Required to File Form No. 104
| Sl. No. | Document Required | Remarks |
|---|---|---|
| 1 | Instrument of creation (Trust Deed, etc.) | Self-certified copy, if created under an instrument |
| 2 | Document evidencing creation/establishment | Self-certified copy, if not created under an instrument |
| 3 | Registration certificate | Self-certified copy issued by ROC / Registrar of Firms & Societies / Registrar of Public Trusts, as applicable |
| 4 | FCRA Registration Certificate | Self-certified copy, if registered under FCRA, 2010 |
| 5 | Order of rejection/cancellation | Self-certified copy of rejection or cancellation under relevant provisions of IT Act, 1961 or IT Act, 2025 |
| 6 | Annual Accounts (up to 3 preceding tax years) | Required, if applicant existed in earlier years and return of income was not filed for last tax year; NIL declaration if no accounts |
| 7 | Note on proposed activities | Brief write-up on proposed activities of the applicant |
Key Features of New Form No. 104 and Benefits to Stakeholders
| Sl. No. | Key Feature of New Form | Benefit to Stakeholders |
|---|---|---|
| 1 | The overall Form No. 104 has been substantially simplified and its length significantly reduced. | Shorter and simpler form minimises effort and time involved in filing Form No. 104, especially for first-time applicants. |
| 2 | Details of assets and liabilities have been removed from the main form and are now required only to be uploaded where the applicant has not filed the return of income. | This will avoid unnecessary disclosures for applicants and will ease the compliance procedure. |
| 3 | Requirement to provide break-up of total income and details of religious expenditure for past three tax years have been completely removed from the form. | Leaner form with fewer data points enables quicker processing of applications. |
5 Key Benefits of the New Simplified Form No. 104
- Significant Ease for New NPOs: Form No. 104 has been substantially simplified, making it easier for newly formed non-profit organisations to obtain automatic provisional registration or approval.
- Reduced Initial Compliance: Detailed information relating to assets, liabilities, income break-ups, and religious expenditure has been removed from the main Form, reducing the reporting requirements at the entry stage.
- Risk-based Information Collection: Asset and liability details are now sought only in cases where the applicant has not filed a return of income, reflecting a more targeted and pragmatic approach.
- Faster & Smoother Registration Process: Overall simplification of Form No. 104 will expedite processing, reduce errors, and encourage voluntary compliance.
- Smart, Technology-Enabled Filing: Auto-population of taxpayer details reduces manual effort and errors, ensuring accuracy from the very first step.
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