Rajeev Mardia
And Associates

Non-profit organisations moving into the Income-tax Act, 2025 framework now have a consolidated electronic application route through Form 105 for regular registration under section 332(3), approval for donation-related deductions under section 354(2), or both.

The Income Tax Department’s newly available Form 105/107 manual confirms that Form 105 is used where activities have commenced, provisional registration is approaching expiry, an existing registration requires renewal, or the organisation’s objects have been modified.

After examination of the application, the Department issues its order through Form 107. Where registration or approval is granted, Form 107 carries a 16-digit Unique Registration Number (URN) that becomes an important identifier for future compliances.

There is also a useful procedural safeguard: if an organisation discovers an error after filing Form 105, the portal permits the application to be withdrawn within seven days of filing. After that seven-day period, withdrawal is no longer available.

Business impact

Trusts, foundations, Section 8 companies and other eligible NPOs should treat the migration as more than a form-number change.

Form 105 collects information across six panels, including the organisation’s recognition history, office bearers, operations, assets and liabilities, income, religious activities and supporting attachments. The registration exercise therefore needs coordination between tax records, governance records and financial statements.

The Department also provides different registration periods in specified circumstances under section 332, while approval under section 354 follows the applicable statutory period. The correct section and section code should therefore be determined before the application is started rather than selected mechanically on the portal.