Wednesday, 31 May 2023

CBDT provides procedural reliefs and clarifications applicable to charitable institutions

This Tax Alert summarizes Circular No. 6/2023 dated 24 March 2023 (Circular) issued by the Central Board of Direct Taxes (CBDT), for extending certain due dates applicable to charitable trusts and other eligible institutions (Charitable Institutions) and various other aspects affecting compliance arising out of certain amendments made by Finance Act 2023.


The key highlights from the Circular are as follows:

Finance Act 2023 has with effect from tax year 2022-23, amended the scope of exit tax by including cases of default by existing charitable institutions in migrating to new regime of registration process introduced in 2021 or charitable institutions with provisional registration have failed to apply for final registration. Under exit tax levy, taxpayer is liable to pay tax at maximum marginal rate on the accreted income being excess of fair value of assets over amount of liabilities.

Prior to amendment, CBDT had from time-to-time extended due date of compliance of registration/renewal. For migration of existing trust to new regime, last extended due date was 25 November 2022 and for final registration of provisionally registered trust, 30 September 2022. In order to mitigate hardships caused to charitable institutions who failed to migrate to new regime or who have failed to apply for final registration or provisional registration by due dates, circular grants extended time for compliance up to 30 September 2023. Once such belated application within such extended time made is accepted and registration is granted, provision of exit tax levy is not to apply.

Consistent with extension so provided also to the charitable institution which is approved under ITL as an entity donation to which will qualify for deduction in the hands of donors, the due date for furnishing statement of donation in Form 10BD by such charitable institutions and donation certificate in Form 10BE for receipt of donation during FY 2022-23 is extended to 30 June 2023.

Further, the Finance Act 2023 prepones the date of furnishing statement of accumulation in Form 10 and deemed application in Form 9A to at least two months prior to due date of furnishing return of income. In deference to the concerns raised that such statements are linked to finalization of total income which may be done around due date of filing tax return, Circular clarifies that the charitable institutions shall not be denied exemption as long as the statement of accumulation/deemed application of income is furnished on or before the due date of furnishing return of income.

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