Since the 2023 rewrite, the question for a registered trust is no longer “which section am I registered under?” It is “how big am I, and where did my money come from and go?”
Get that wrong and you file the wrong audit report — which is a real problem, not a formatting one. Form 10B is the larger of the two, and three separate triggers can force you into it.
At a glance
- What it is
- The larger audit report for registered trusts and institutions
- Rules
- Rules 16CC and 17B, as rewritten with effect from 1 April 2023
- Who signs
- A Chartered Accountant in practice
- Deadline
- One month before the return due date
- Trigger
- Income above ₹5 crore, or foreign contribution, or income applied outside India
- The alternative
- Form 10BB, where none of those apply
- Under the 2025 Act
- Audit obligation at section 348
The three triggers
You must file Form 10B if any one of these is true for the year:
| Trigger | Test |
|---|---|
| Size | Total income, computed without giving effect to sections 11 and 12, exceeds ₹5 crore |
| Foreign money | The trust received any foreign contribution during the year |
| Overseas application | The trust applied any part of its income outside India during the year |
If none apply, Form 10BB is available instead.
Income is measured before exemption. The ₹5 crore test ignores sections 11 and 12 — so a trust that applies all its income and pays no tax can still be well over the threshold. Trusts routinely test this on their taxable figure, conclude they are small, and file the wrong form.
Any foreign contribution at all. There is no minimum. A single FCRA receipt during the year pushes the trust into Form 10B regardless of size.
The misconception worth clearing up
Before 2023, practitioners associated Form 10B with section 12A registration and Form 10BB with the section 10(23C) route. That association no longer holds.
Both forms now serve both routes. The choice depends entirely on the three triggers above. A large 10(23C)-approved institution files Form 10B; a small 12A-registered trust files Form 10BB. Which provision you registered under does not decide it.
What Form 10B asks for
Form 10B is materially more demanding than 10BB. Its schedules cover:
- Registration or approval particulars, and any change during the year
- Objects, and whether activities were carried on in accordance with them
- Voluntary contributions, split between corpus and non-corpus, and their investment
- Application of income, including amounts applied outside India and the approval relied on
- Accumulation under section 11(2), with the purpose and the investment of accumulated funds
- Payments to specified persons under section 13(3) — the related-party question
- Business income and whether the business is incidental to the objects, with separate books
- Foreign contribution received, and FCRA registration particulars
- Investments held, tested against the permitted modes in section 11(5)
- TDS compliance and other statutory matters
Section 13(3) is where exemption is most often lost. Payments, loans, rent, or use of property involving trustees, founders, substantial contributors and their relatives can forfeit exemption on the amount involved. Form 10B asks for these directly, so the schedule has to be built from the ledger rather than from a management assurance that “there are none”.
Deadline
The audit report is due one month before the due date for furnishing the return — so 30 September where the return is due 31 October. It is filed electronically by the CA and must then be accepted by the trust.
Filing 10BB when 10B was required is treated as not filing at all. The consequence is that the audit report is not furnished, which puts the exemption under sections 11 and 12 at risk for the entire year. Trusts have had to seek condonation of delay after discovering this. Establish which form applies before the audit starts, not at the point of upload.
UDIN on Form 10B
Form 10B is an audit report, so it falls in the Audit and Assurance Functions category, where UDIN has been mandatory since 1 July 2019 — a different category and date from the certificate-type forms.
The e-filing rule is the same and unforgiving: a form uploaded without a UDIN must have the number updated within 60 calendar days, or the CBDT treats it as invalid with all due consequences of law, even after the trust has accepted it. Revocation closes at 48 hours. Details in our guide to UDIN generation.
Trust audit under the Income-tax Act, 2025
The 2025 Act gathers the whole charitable regime into a dedicated part — sections 332 to 355, “Special provisions for registered non-profit organisation”. Per ICAI’s tabular mapping:
| Subject | 1961 Act | 2025 Act |
|---|---|---|
| Registration and approval | Sections 11, 12A, 12AB, 80G | Section 332 |
| Tax on income of the organisation | Sections 11, 12, 13, 115BBC, 115BBI | Section 334 onwards |
| Application of income | Section 11 | Section 341 |
| Accumulated income | Section 11(2) | Section 342 |
| Audit | Sections 11, 12A and 139 | Section 348 |
| Return of income | Section 139 | Section 349 |
| Permitted modes of investment | Section 11(5) | Section 350 |
Registration applications also renumber: Form 10A becomes Form 104 and Form 10AB becomes Form 105, the latter described as registration of a non-profit organisation under section 332.
Frequently asked questions
When must a trust file Form 10B rather than 10BB?
If income before sections 11 and 12 exceeds ₹5 crore, or any foreign contribution was received, or any income was applied outside India. Any one is enough.
Is the ₹5 crore tested on taxable income?
No — on total income computed without giving effect to sections 11 and 12, so before exemption.
Does a small foreign donation force us into Form 10B?
Yes. There is no minimum; any foreign contribution during the year triggers it.
Does Form 10B still go with section 12A and 10BB with 10(23C)?
No. That link was broken when the forms were rewritten in 2023. Both forms serve both routes; the three triggers decide.
What happens if we file the wrong form?
Filing 10BB where 10B was required is treated as the audit report not having been furnished, which puts the year’s exemption at risk.
When is the report due?
One month before the return due date — 30 September where the return is due 31 October.
Who has to accept the form?
The CA uploads it and the trust must accept it on the portal. Until acceptance the filing is not complete.
Which UDIN category applies?
Audit and Assurance Functions, mandatory since 1 July 2019 — not the Certificates category.
What is the section 13(3) schedule about?
Payments and benefits involving trustees, founders, substantial contributors and their relatives. These can forfeit exemption on the amounts involved, so the form asks for them expressly.
Where does the audit requirement sit under the new Act?
Section 348, within the registered non-profit organisation provisions at sections 332 to 355.
Do the registration forms change?
Yes. Form 10A becomes Form 104 and Form 10AB becomes Form 105 under the 2025 Act.
In short
Form 10B is the trust audit report for anyone above ₹5 crore before exemption, anyone touching foreign contribution, and anyone spending abroad. Test those three at the planning stage, because the cost of choosing wrongly is not a resubmission — it is the year’s exemption. Under the 2025 Act the obligation lives at section 348, inside a much tidier non-profit chapter.
Micro Advisor audits charitable trusts, societies and Section 8 companies, and advises on registration and exemption compliance.
References
Disclaimer. General information, not professional advice. Thresholds, forms and the charitable regime have been amended repeatedly; verify the position for the trust and year concerned.