VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.12AB registration periods, the Finance Act 2025 ten-year proviso for small trusts, and the Finance (No. 2) Act 2024 power to condone a late application
CBDT Circulars & InstructionsCuts both wayss.12ABs.12AB(1)s.12AB(2)s.12AB(3)s.12AB(4)s.12AB(5)s.12As.12A(1)(ac)s.80G(5)s.119

Statutory position — s.12AB registration periods, the Finance Act 2025 ten-year proviso for small trusts, and the Finance (No. 2) Act 2024 power to condone a late application

How long does registration under s.12AB now run, is the ten-year period for small trusts real, and is there still any way to save a late Form 10A or Form 10AB?

How long does registration under s.12AB now run, is the ten-year period for small trusts real, and is there still any way to save a late Form 10A or Form 10AB?

Registration under s.12AB(1)(a) and under s.12AB(1)(b)(ii)(A) runs five years; provisional registration under s.12AB(1)(c) runs three years from the assessment year for which registration is sought. The ten-year period is real but narrower than it is usually described: a proviso to s.12AB(1) inserted by the Finance Act 2025 (Act No. 7 of 2025) with effect from 1 April 2025 substitutes ten years for five where the application is under sub-clauses (i) to (v) of s.12A(1)(ac) and the total income of the trust, without giving effect to ss.11 and 12, did not exceed rupees five crores in each of the two previous years preceding the previous year in which the application is made — it does not lengthen the three-year provisional registration under clause (c). Separately, a proviso to s.12A(1)(ac) inserted by Act No. 15 of 2024 with effect from 1 October 2024 empowers the Principal Commissioner or Commissioner to condone a delay in filing where he considers there is a reasonable cause, and the application is then deemed to have been filed within time.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2025-04-01, reported as Finance Act, 2025 (Act No. 7 of 2025), w.e.f. 1 April 2025; Finance (No. 2) Act, 2024 (Act No. 15 of 2024), w.e.f. 1 October 2024. It bears on section 12AB, section 12AB(1), section 12AB(2), section 12AB(3), section 12AB(4), section 12AB(5), section 12A, section 12A(1)(ac), section 80G(5), section 119 of the Income Tax Act 1961, in Charitable Trusts & Exemption, Capital Gains Exemptions and How Tax Law Is Read matters.

Still good law. The text was read on two independently year-stamped departmental pages, Year 2025 and Year 2026, both carrying the section heading "Procedure for fresh registration", and the two agree word for word on every provision quoted here; the amendment footnotes on the 2026 pages attribute the ten-year proviso to Act No. 7 of 2025 with effect from 1 April 2025 and the condonation proviso to Act No. 15 of 2024 with effect from 1 October 2024. The commencement of the condonation proviso is separately confirmed by three tribunal orders read for this batch. I did not check for any amendment made after the 2026 page was stamped, and I could not confirm from a departmental circular index that no extension circular later than Circular 7/2024 exists.

Why it matters

Three things in this framework are routinely got wrong. First, the ten-year proviso is being described as extending 'provisional and final registration' to ten years for small trusts; it does not touch provisional registration at all, and the income test is applied to the two previous years preceding the previous year in which the application is made, not to the year of application. Second, the condonation power exists for registration under s.12A(1)(ac) and does not by its terms extend to approval under s.80G(5) — for a late s.80G application the route is clause (iv)(B) of the first proviso to s.80G(5) — a clause the same Act did not insert but opened up from the same date, by omitting the words that had confined item (B) to an institution no part of whose income had been excluded under sub-clause (iv), (v), (vi) or (via) of s.10(23C) or under s.11 or s.12 for any previous year ending on or before the date of application (footnote 95a on the departmental page, "omtt. by Act No. 15 of 2024, w.e.f. 1-10-2024"), and by omitting the opening words "in any other case," from clause (iv). Third, s.12AB(4) is not a general power of cancellation: it operates only on one of the seven specified violations set out in the Explanation, and only where one of the three triggers in clauses (a) to (c) is present, and any order under it is subject to the six-month limitation in s.12AB(5), which runs from the end of the quarter in which the first notice calling for documents or information was issued on or after 1 April 2022 — not from the date the violation is discovered. The time limits in s.12AB(3) for disposing of the application are also frequently overlooked: three months from the end of the month for a clause (a) application, six months from the end of the quarter for a clause (b)(ii) application, and one month from the end of the month for a clause (c) provisional registration.

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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