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Section 332 · Special persons

Section 332 of the Income-tax Act, 2025 — Application for Registration of a Non-Profit Organisation (Charitable Trust/Institution)

By CA Rajat Agrawal Updated 05 Jul 2026 Chapter XVII
📜 What the law says — Section 332, Income-tax Act 2025
332. (1) The following persons may, for claiming benefits under this Part as a registered non-profit organisation, make an application for registration in such form and manner, as may be prescribed, to the Principal Commissioner or Commissioner:— (a) a public trust; or (b) a society registered under the Societies Registration Act, 1860 (21 of 1860), or under any law in force in India; or (c) a company registered under section 8 of the Companies Act, 2013 (18 of 2013) or the companies registered under section 25 of the Companies Act, 1956 (1 of 1956) and deemed to have been registered in pursuance of section 465(2)(g) of the Companies Act, 2013 (18 of 2013); or (d) a University established by law or any other educational institution affiliated thereto or recognised by the Government; or (e) an institution financed wholly or in part by the Government or a local authority; or (f) any person as referred to in Schedule III (Table: Sl. No. 27) to (Table: Sl. No. 29) and (Table: Sl. No. 36) and in 64[Schedule VII (Table: Sl. Nos. 17 to 19)] and (Table: Sl. No. 42); or (g) any other person notified by the Board in this behalf. (2) A person referred to in sub-section (1) shall be eligible for registration, if— (a) such person is constituted or registered or incorporated in India for carrying out one or more charitable purposes, as referred to in section 2(23) or one or more public religious purposes; and (b) the properties of such person are held for the benefit of the general public under an irrevocable trust— (i) wholly for charitable or religious purposes in India; or (ii) partly for charitable or religious purposes in India, if such person was constituted or registered or incorporated prior to the com- mencement of the Income-tax Act, 1961 (43 of 1961). (3) Every application in respect of the cases specified in column B of the Table below shall be made to the Principal Commissioner or Commissioner within the time provided in column C of the said Table, who shall, on receipt of such application, follow the procedure provided in this section and shall pass an order within the time specified in column D of the said Table, and registration, if granted, shall be valid for a period specified in column E ther
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In plain language

What Section 332 is about

Section 332 of the Income-tax Act, 2025 (effective 1 April 2026) is the single gateway through which a charitable trust, society, Section 8 company, university, hospital or other charitable/religious institution obtains tax registration and becomes a Registered Non-Profit Organisation (RNPO). Only a registered NPO can access the exemption regime in Sections 334 to 337 (the successor to Sections 11, 12 and 10(23C) of the 1961 Act). Without registration under Section 332, the entity is taxed like any ordinary person on its full income.

The 2025 Act consolidates what used to be a fragmented system — Section 12A (fresh registration), Section 12AB (procedure and renewal) and the Section 10(23C) approval route — into one unified application under Section 332.

Who can apply

  • Public charitable or religious trusts holding property under an irrevocable trust for the benefit of the general public.
  • Societies registered under the Societies Registration Act, 1860.
  • Section 8 companies (and deemed Section 25 companies of the old Companies Act).
  • Universities and educational institutions, hospitals, and government/local-authority financed institutions.
  • Specified persons in Schedules III and VII and any other person notified by the Board (CBDT).

Two core conditions must be met: the entity must be constituted or registered in India for charitable purposes as defined in Section 2(23) or for public religious purposes, and its property must be held under an irrevocable trust for the benefit of the general public.

The seven application scenarios

Section 332 lays down a table covering seven situations, each with its own deadline, order timeline and validity period:

  • Brand-new NPO, activities not yet begun — apply any time; order within roughly a month; provisional registration for 3 years.
  • Activities already commenced, never registered — order within 6 months from quarter-end; 5 years.
  • Converting provisional registration after activities begin — apply within 6 months of commencement; 5 years.
  • Registration/provisional registration expiring — apply at least 6 months before expiry; 5 years.
  • Registration made inoperative (Section 333) — re-apply; 5 years.
  • Objects modified that do not conform to existing registration — apply within 30 days; 5 years.

The 10-year rule for small NPOs

Small organisations get a longer, less burdensome cycle. Where total income does not exceed ₹5 crore in each of the two preceding tax years, the registration on renewal/regular grant is valid for ten years instead of five. This reduces the compliance frequency for genuinely small trusts.

Who decides, and by when

  • The application is decided by the Principal Commissioner or Commissioner.
  • For provisional (new) applicants, registration is essentially granted; for others the officer examines the genuineness of activities, the objects, and compliance with other applicable laws before granting or rejecting.
  • Rejection or cancellation can only be done after giving the applicant a reasonable opportunity of being heard.

Practical implications and interaction with other sections

  • Delay can be condoned: under Section 332(4) the Commissioner may condone a late application for reasonable cause.
  • Miss the deadline without condonation and you pay tax on accreted income under Section 352 — the exit-tax equivalent of the old Section 115TD. This is a serious financial consequence, so timelines must be tracked carefully.
  • Registration feeds the exemption in Sections 334–337; it can be made inoperative or cancelled under Section 333.
  • Transition relief: entities holding a valid, uncancelled registration/approval under the 1961 Act on 1 April 2026 are treated as RNPOs automatically — no fresh application is required at cut-over.

In short, Section 332 is the front door to the entire NPO tax-exemption ecosystem under the 2025 Act. Every trust or institution should diary its registration expiry, file at least six months ahead for renewals (30 days for object changes), and keep governing documents, PAN, and activity records ready.

💡 Example

Example 1 — A brand-new trust (provisional route): "Asha Vidya Foundation" is set up in June 2026 as a public charitable trust to run free tuition centres, but has not yet started activities. It applies under Section 332 in the pre-commencement category. It receives provisional registration valid for 3 tax years (2026-27 to 2028-29). Once it actually begins running centres in, say, October 2026, it must apply within 6 months of commencement to convert to regular registration, which is then granted for 5 years.

Example 2 — A small trust and the 10-year benefit: "Seva Medical Relief Society" has total income of ₹3.2 crore and ₹4.1 crore in the two preceding tax years — both below ₹5 crore. When it applies for renewal on expiry, because it satisfies the small-NPO test, its registration is granted for 10 years instead of 5, halving the frequency of renewal filings and inspection.

A relatable story: Rajesh, treasurer of a neighbourhood cultural-and-education trust, assumed the old "one-time" 12A registration was permanent. Under the 2025 Act his registration was due to expire, and he learned that a renewal application must be filed at least 6 months before expiry. He filed just in time. His friend running another trust missed the window, could not get condonation, and his trust became liable to tax on accreted income under Section 352 — a costly reminder that registration is now term-based and must be actively renewed.

Situation of the applicantWhen to applyType / validity of registration
New NPO, activities not yet commencedAny time during the tax yearProvisional — 3 tax years
Activities commenced, never registeredAny time during the tax yearRegular — 5 years
Provisional holder, activities now startedWithin 6 months of commencementRegular — 5 years
Existing registration/provisional expiringAt least 6 months before expiryRegular — 5 years (10 years if small)
Registration made inoperative (Sec 333)During the tax year soughtRegular — 5 years (10 years if small)
Objects modified / non-conformingWithin 30 days of modificationRegular — 5 years (10 years if small)
Small NPO (income ≤ ₹5 cr in each of 2 preceding years)As per relevant row above10-year validity on renewal/regular grant

Related sections

Section 333 — Registration becoming inoperative and cancellation of RNPO registration Section 334 — Income of a registered non-profit organisation not included in total income Section 335 — Commercial activities and application of income by an RNPO Section 352 — Tax on accreted income (exit tax) of a non-profit organisation Section 2(23) — Definition of 'charitable purpose' Section 355 — Definitions for the non-profit organisation regime (including RNPO)

Forms under this section

Income-tax forms (2025) prescribed under Section 332:

📄 Form 105 (was 10AB)

Frequently asked questions

Is registration under Section 332 permanent like the old 12A registration?
No. Under the 2025 Act registration is term-based — 3 years for provisional, and 5 years (or 10 years for small NPOs with income up to ₹5 crore) for regular registration, requiring renewal before expiry.
What happens if I miss the renewal deadline?
If you do not apply within the prescribed time and the delay is not condoned by the Commissioner, the organisation becomes liable to pay tax on its accreted income under Section 352 — effectively an exit tax on the accumulated corpus.
Do trusts already registered under the 1961 Act need to re-apply on 1 April 2026?
No. Entities holding a valid, uncancelled registration or approval under the old Act on 1 April 2026 are automatically treated as Registered Non-Profit Organisations under the new Act, with no fresh application needed at the cut-over.
Which authority grants registration under Section 332?
The Principal Commissioner or Commissioner of Income-tax decides the application, examining the genuineness of activities, the objects, and compliance with other applicable laws before granting or rejecting registration.
How much advance notice is needed for renewal?
Renewal applications for an expiring registration or provisional registration should generally be filed at least six months before expiry; if the objects are modified in a way that does not conform to the existing registration, you must apply within 30 days.
When can a new trust get only provisional registration?
A brand-new NPO that has not yet commenced its activities is given provisional registration valid for three tax years; once activities begin it must apply to convert to regular registration within six months of commencement.
What is the ₹5 crore threshold for?
If an NPO's total income did not exceed ₹5 crore in each of the two tax years preceding the application, it qualifies as a small NPO and gets a 10-year registration validity on renewal instead of the standard 5 years.
C
CA Rajat Agrawal
Chartered Accountant, EaseValue · Reviewed 05 Jul 2026
This explainer is prepared and reviewed by EaseValue's tax team, based on the text of the Income-tax Act, 2025 (as amended by the Finance Act, 2026).
Disclaimer: This page explains the law in general terms for education and is not professional advice. The Income-tax Act, 2025 takes effect from 1 April 2026; provisions, thresholds and interpretations may change. Please confirm your specific position with our team before acting.

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