Income Tax Form 105: A Comprehensive Guide to NPO Registration Under Section 332 and Approval Under Section 354 of the Income Tax Act, 2025

Overview and Background

The Income Tax Act, 2025 has introduced a restructured compliance framework for non-profit organisations (NPOs) operating in India. As part of this overhaul, Form No. 105 has been introduced as the consolidated application mechanism through which NPOs can obtain regular registration under Section 332 or seek approval under Section 354 of the Income Tax Act, 2025. This replaces the earlier Form No. 10AB that existed under the Income-tax Rules, 1962.

The table below captures the regulatory mapping of the old and new framework:

This unified form eliminates the need for separate filings and brings together the registration and approval processes under a single submission, significantly reducing the compliance burden on charitable and religious institutions.

What Is Form No. 105?

Form No. 105 serves as a single, consolidated application for two distinct purposes:

1. Registration Purpose – Any NPO seeking regular registration under Section 332(3) (Table: Sl. Nos. 2 to 7) of the Income Tax Act, 2025, in order to access the tax benefits available to registered non-profit organisations.

2. Approval Purpose – Any registered NPO, or any regimental Fund or Non-public Fund established by the armed forces of the Union as referred to in Schedule VII (Table: Sl. No. 1) of the Income Tax Act, 2025, seeking approval under Section 354(2) (Table: Sl. Nos. 2 to 5), so that donations received by such organisations or funds qualify for deduction under Section 133(1)(b)(ii) of the Act in the hands of donors.

Important: An assessee seeking both regular registration and regular approval does not need to file two separate forms. A single Form No. 105 suffices for both purposes. Upon processing, the Principal Commissioner or Commissioner will issue two separate orders in Form No. 107 — one for registration and one for approval.

Who Is Required to File Form No. 105?

Category 1: Applicants Seeking Regular Registration

Every NPO falling under Section 332(1) of the Income Tax Act, 2025, that satisfies the eligibility criteria prescribed under Section 332(2) — such as being registered or incorporated in India for charitable or religious objectives — is required to file Form No. 105 if it falls under any of the following situations:

• The NPO has commenced activities but has never been registered under Section 12A, Section 12AA, or Section 12AB or Section 10(23C) of the Income-tax Act, 1961, or Section 332 of the Income Tax Act, 2025
• The NPO holds provisional registration and its activities have since commenced
• The provisional registration is nearing expiry and activities are yet to begin
• The existing registration is approaching expiry (other than the provisional expiry scenario above)
• The registration has become inoperative owing to a regime change under Section 333 of the Income Tax Act, 2025
• The NPO, being already registered, has modified its objects in a manner inconsistent with the conditions of registration

Category 2: Applicants Seeking Regular Approval

Any registered NPO or regimental/non-public fund of the armed forces (Schedule VII, Table Sl. No. 1), seeking approval under Section 354(2) to enable donor deductions under Section 133(1)(b)(ii), must file Form No. 105 if:

• Activities of the organisation have commenced
• The organisation holds provisional approval and activities have commenced
• The provisional approval is approaching expiry and activities have not yet commenced
• The existing period of approval for the registered NPO is due to expire

Filing Deadlines: Time Limits for Submitting Form No. 105

The deadline for filing Form No. 105 varies depending on the specific situation of the applicant. The following schedule applies: