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Case lawCBDT Circulars & Instructions › CBDT Circular No. 2/2024 — audit report filed in the wrong form
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CBDT Circular No. 2/2024 — audit report filed in the wrong form

For AY 2023-24 my trust filed Form 10B when Form 10BB was the right form. Is there a CBDT relaxation, and what exactly does it cover?

For AY 2023-24 my trust filed Form 10B when Form 10BB was the right form. Is there a CBDT relaxation, and what exactly does it cover?

Yes, but it is narrow. By Circular No. 2/2024 dated 5 March 2024 the CBDT allowed trusts and institutions that had furnished an audit report on or before 31 October 2023 in Form No. 10B where Form No. 10BB was applicable, and vice versa, to furnish the audit report in the applicable form for AY 2023-24 on or before 31 March 2024. It covers only AY 2023-24, only a wrong-form filing that was itself made by 31 October 2023, and the window it gave has closed.

Decided by the CBDT Circulars & Instructions (Central Board of Direct Taxes) on 2024-03-05, reported as Circular No. 2/2024, F.No.370142/6/2024-TPL, dated 5 March 2024. It bears on section 10(23C), section 11, section 12, section 12A, section 12AB, section 119 of the Income Tax Act 1961, in Charitable Trusts & Exemption and Capital Gains Exemptions matters.

Validity check could not be completed. Validity check could not be completed and the entry rests on the Ministry of Finance press release rather than on the circular itself, which could not be retrieved. No later circular superseding, extending or withdrawing Circular No. 2/2024 was searched for. On its own terms the relaxation window closed on 31 March 2024, so the circular is spent as a filing route and is now of use mainly as a statement of the Board's position on wrong-form filings for AY 2023-24.

Why it matters

The relaxation exists because AY 2023-24 was the first year in which the choice between Form 10B and Form 10BB stopped following the exemption route taken and started following a threshold test, and a large number of trusts picked the wrong one. Getting the boundaries right matters because the circular is repeatedly cited for more than it says. It does not help a trust that filed nothing by 31 October 2023, it does not help AY 2022-23 or earlier, and its own window expired on 31 March 2024. A trust outside those limits is back to s.119(2)(b) condonation and to the Tribunal line that treats the wrong form as a curable procedural defect — and s.119(2)(b) condonation for Form 10B and Form 10BB is itself the subject of Circular No. 16/2024 of 18 November 2024, which covers AY 2018-19 and subsequent years. The circular is also the clearest official confirmation of why the problem arose at all, and of the Board's own view that non-furnishing of the audit report in the prescribed form would otherwise result in denial of exemption and creation of a demand — which is exactly what the CPC does. For the underlying test, the department's published guidance is that Form 10B is required where total income computed without giving effect to ss.11 and 12 or s.10(23C)(iv), (v), (vi) or (via) exceeds Rs 5 crore, or where foreign contribution has been received, or where any part of the income has been applied outside India, and Form 10BB where all three of those are absent.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

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