VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawConcepts › Applying 85%, accumulating the rest, and where you may park it

Applying 85%, accumulating the rest, and where you may park it

My trust could not spend 85% of its income this year — can I accumulate it, and where must the money sit?

My trust could not spend 85% of its income this year — can I accumulate it, and where must the money sit?

Yes, but only if you file Form 10 specifying the purpose, apply the money within five years, and keep it invested only in the modes listed in section 11(5). The baseline is that 85% of income must be applied to the objects each year; 15% may be retained without any condition.

This is an explainer, not a judgment. It states the law in our own words, which is exactly why it needs checking. Everything below was written from the sources listed at the foot of this page, and no chartered accountant has yet signed it off. Read the source before you rely on it in a reply or an appeal.

Section 11 exempts a registered trust's income to the extent it is applied to charitable or religious purposes in India during the year. The department's own guidance puts the threshold at 85% of income; the balance up to 15% can be accumulated indefinitely with no conditions attached, no form to file and no restriction on where it sits.

If you cannot apply 85%, section 11(2) lets you accumulate the shortfall — but as a bargain, not a right. You must give notice in Form 10 stating the specific purpose and the period, the accumulation cannot run beyond five years, and the money must be invested or deposited in one of the forms or modes specified in section 11(5).

The Form 10 deadline moved. From AY 2023-24 the notice has to be filed at least two months before the due date for furnishing the return under section 139(1), not with the return. The idea is that the auditor reporting in Form 10B/10BB can see it. The same two-month rule applies to Form 9A, the separate option under Explanation 1 to section 11(1) where income has not actually been received in the year or was received too late to spend.

Section 11(5) is a closed list, and it is conservative. It covers small savings certificates and other Central Government savings-scheme securities, Post Office Savings Bank deposits, deposits with a scheduled bank or a co-operative bank, units of the Unit Trust of India, Central or State Government securities, debentures whose principal and interest are guaranteed by the Central or a State Government, shares or deposits in public sector companies, bonds of approved financial corporations providing long-term industrial finance, bonds of approved public companies providing housing finance, immovable property excluding plant and machinery, deposits with public companies providing long-term urban infrastructure finance, deposits with IDBI, and any other form prescribed by rule. Mutual fund units come in through the prescribing rule.

Section 11(3) is what bites if you slip. Accumulated income becomes deemed income of the trust if it is applied to a purpose other than the one notified, if it ceases to be invested in the section 11(5) modes, or if it is not applied within the five years. Equity shares of a listed private company, a loan to a trustee, or an unlisted debenture are not section 11(5) modes, and parking accumulated money there is not just a technical breach — it is one of the section 13 grounds on which exemption is withdrawn, and one of the six specified violations for which registration can be cancelled.

Two Finance Act 2023 changes tightened what counts as application. Where a trust donates to another trust, only 85% of that donation counts as application in the donor's hands from AY 2024-25, so passing money down a chain of trusts no longer works cleanly. And from AY 2023-24, replenishing a corpus you had spent, or repaying a loan or borrowing you had treated as application, counts as application only if done within five years from the end of the year of the original utilisation, and never for amounts spent before 1 April 2021.

One more condition sits outside section 11 itself. Section 12A(1)(ba) requires the return to be filed within the time allowed, and from AY 2023-24 the exemption survives if the return is filed within the section 139(1) or 139(4) window. Miss even that and the accumulation and application arithmetic never gets reached.

Why it matters

The 85% rule and the Form 10 route are the day-to-day mechanics of a trust's exemption, and the deadlines are now earlier than the return itself. Accumulating without Form 10, or holding accumulated funds outside the section 11(5) list, converts exempt income into taxable deemed income under section 11(3) and simultaneously exposes the registration to cancellation. The five-year clock also means an accumulation made today has to be tracked for five years, not one.

What to do

Where people go wrong

Unsettled, or not pinned down. The official Income Tax Department guidance note I fetched still describes the Form 10 deadline as the section 139(1) due date, which was the pre-AY 2023-24 position; the two-month rule comes from the department's newer trust-taxation page and from commentary on the Finance Act 2023. I did not fetch the bare text of section 11(2), 11(3) or 11(5) itself, only the department's summaries and a reckoner listing. Under the Income-tax Act, 2025 (in force from 1 April 2026) these provisions move to sections 335, 336, 342 and 350 read with Schedule XVI, with investments outside the permitted modes taxed as "specified income".

Authorities on these sections

Judgments in this library that turn on the same provisions.

Where this came from

Every page in this library links to what it was written from, so you can check it rather than take our word for it.