Form 15 Under Income Tax Act 2025: Annual Statement for Scientific Research Donations Under Section 45(4)(a)

Overview

The Income-tax Act, 2025 has introduced a dedicated compliance mechanism for institutions and undertakings engaged in receiving contributions for research purposes. Form 15 is a statutory annual electronic statement that must be filed by prescribed entities under Section 45(4)(a) of the Income-tax Act, 2025, in respect of sums received towards scientific, social science, or statistical research during any given tax year.

This reporting obligation represents a deliberate policy move toward purpose-specific, segmented compliance — separating the reporting framework for scientific research donations from the broader charitable donation ecosystem. Understanding Form 15 is essential for research associations, universities, approved companies, national laboratories, and other qualifying institutions to ensure uninterrupted deduction eligibility for their donors and to avoid adverse compliance consequences.

Legislative Basis and Historical Context

Statutory Foundation

Form 15 derives its authority from Section 45(4)(a) of the Income-tax Act, 2025. This provision mandates that every prescribed undertaking or institution falling within the scope of Section 45(3) must furnish an annual statement capturing details of all eligible sums received during the tax year.

Continuity from the 1961 Framework

To appreciate the relevance of Form 15, it is helpful to trace its legislative lineage:

  • Section 45(3) of the Income-tax Act, 2025 corresponds to Section 35(1)(i), (ii), and (iia) of the Income-tax Act, 1961
  • Section 45(4)(a) of the Income-tax Act, 2025 corresponds to Section 35(1A) of the Income-tax Act, 1961
  • Form 15 replaces Form 10BD to the extent that Form 10BD previously covered scientific research donations under the 1961 Act, which was governed by Rule 18AB of the Income-tax Rules, 1962

Key Continuity Point: The due date of 31st May has been retained from the earlier framework applicable to Form 10BD under Rule 18AB. This ensures that institutions transitioning from the 1961 Act regime face minimal disruption while adapting to the new compliance structure.

The Income-tax Act, 2025, however, introduces a critical structural change — Form 15 applies exclusively to scientific research donations, whereas Form 10BD under the old framework also covered donations to charitable institutions under Section 80G. Under the new regime, charitable donations are governed by a separate reporting framework through Form 113.

Who Must File Form 15?

Entities Covered Under Section 45(3)

The obligation to file Form 15 applies to every prescribed undertaking or institution referred to in Section 45(3) of the Income-tax Act, 2025, provided it has received any eligible sum during the relevant tax year.

Section 45(3) encompasses payments made to the following categories:

  1. A research association engaged in scientific research, or a university, college, or institution receiving sums for scientific research purposes
  2. A research association or institution carrying out social science or statistical research
  3. An approved Indian company engaged in scientific research and development
  4. A national laboratory, university, Indian Institute of Technology, or a specified person as may be prescribed

Who Is NOT Required to File?

  • The donor — the responsibility for furnishing Form 15 rests entirely with the recipient institution, not the contributing entity or individual
  • Institutions that have not received any eligible sum during the relevant tax year are not required to file Form 15 for that year