Filing an NGO’s tax return and audit report

A registered NGO must keep books of account, have them audited by a chartered accountant (CA) and file an income-tax return for every year in which its total income, before the exemption, is above the basic exemption limit (Sections 347 to 349 of the Income-tax Act, 2025). From tax year 2026-27 the audit report is Form 112, due one month before the return, and the return is due by 31 October after the year.

2026 is a changeover year. The audit report and return filed this year are for 2025-26 and still use the 1961 Act’s forms: the audit report in Form 10B or 10BB and the return in ITR-7, with due dates the Central Board of Direct Taxes (CBDT) has moved to 21 October and 21 November 2026.

This guide covers both years: who must file, the forms and dates, what the auditor checks, what happens if you are late, and a calendar. It is for NGO finance teams, trustees and their CAs.

Who must keep books, get an audit and file a return

The same test applies to all three duties:

• Books (Section 347, formerly section 12A(1)(b)(i)),
• an audit by an accountant, with the report in the prescribed form (Section 348, formerly section 12A(1)(b)(ii)), and
• a return of income (Section 349, formerly sections 12A(1)(ba) and 139(4A)),

are required for any tax year in which the organisation’s total income, before the exemption, exceeds the basic exemption limit, the level of income on which no tax would be payable.

“Before the exemption” means the NGO’s income is counted before the 85% rule and the other exemption provisions are applied: its donations, grants, fees and interest. So almost any registered NGO with real activity crosses the limit. Many NGOs below it still keep audited accounts and file a return, because funders and CSR teams ask for them.

Other laws add their own duties: a Section 8 company has its Companies Act audit and filings, and an FCRA-registered NGO has its FCRA returns. See accounts and audit for NGOs.

The forms and dates, year by year

The 2026 extension was announced in a CBDT press release of 28 September 2026 for taxpayers whose accounts must be audited, which includes registered NGOs; news reports said a formal order would follow. The dates for 2027 onwards are the dates in the Act (Section 263(1)(c) for the return, and one month before it for the audit report), and the CBDT can extend them. Check the e-filing portal before each deadline.

Form 112: the new audit report

From tax year 2026-27, Form 112 replaces both Form 10B and Form 10BB. It is signed by a CA and filed online. It has a lighter version for a small registered non-profit organisation: one whose regular income in the tax year is up to ₹5 crore, whose foreign contribution is up to ₹10 lakh and whose income applied outside India is up to ₹10 lakh. Under the old rules, any foreign contribution pushed an NGO into the longer Form 10B.

According to practitioners’ summaries of the form, the auditor reports on:

• how the year’s income divides into regular income, specified income and corpus;
• what was applied to the objects, in India and outside it;
• accumulation and deemed application;
• corpus, anonymous and foreign donations;
• transactions with related persons;
• commercial activities, depreciation and loans;
• TDS compliance, and anything that may be a violation under Sections 351 and 353.

What the auditor will ask for

Filing the return

The return is filed under Section 349 by the due date in Section 263(1)(c): 31 October after the tax year for anyone whose accounts must be audited. Two related forms are due by the same date:

• Form 108 (formerly 9A), if the organisation opts for deemed application of income;
• Form 109 (formerly Form 10), if it accumulates income for a stated purpose.

Miss them and the option or the accumulation is lost, even if the return itself is filed later. See the 85% rule.

Late returns. Since the Finance Act, 2026, a return filed late under Section 263(4), within nine months of the end of the tax year or before assessment, whichever is earlier, still satisfies Section 349. A late fee may apply (Section 428, formerly section 234F).

What happens if you don’t comply

If an organisation doesn’t keep books, doesn’t have them audited or doesn’t file its return as Sections 347 to 349 require, Section 353 applies to that year (formerly sections 13(10) and 13(11)):

• its regular income, less its permitted expenditure, is taxable at normal rates. Permitted expenditure means revenue spending in India on the objects, not capital spending, and not paid from the corpus or from loans;
• any specified income and residual income is taxed as well.

A late audit report. Section 353 applies where the books aren’t audited as Section 348 requires. Whether an audit report filed after its due date is treated the same way hasn’t been tested under the new Act, so treat the audit report’s due date as firm.

A filing calendar

For a registered NGO approved for donors’ deduction, with staff, in a year with no extensions:

The TDS deadlines are in TDS for NGOs and the donor statement in donation statements and certificates.

Common mistakes

• Leaving the audit to the last week. The return relies on the audit report, which is due a month earlier.
• Using the wrong year’s forms: ITR-7 and Form 10B or 10BB for 2025-26; Form 112 and the new return from 2026-27.
• Forgetting Form 108 or Form 109, which are due with the return, not after it.
• Not reconciling donations with the statement filed in Form 113, so the auditor’s figures and the donors’ certificates disagree.
• Treating a long registration as a holiday from filing. A ten-year registration still needs books, an audit and a return for every year in which income is above the limit.

The return and audit report are where every other tax rule in this series comes together, so book your CA early, well before the busy weeks before each deadline.