Income Tax Form 104 Replaces Form 10A: New NPO Registration Process Explained

Form No. 104 is the new online application form for provisional registration and provisional approval of eligible nonprofit organisations under the Income Tax Rules, 2026. It is meant for entities that have not yet started their activities but want to enter the tax framework and claim the benefits available to registered NPOs.

The Income Tax Department has presented it as part of a simplification exercise focused on ease of compliance, standardisation and technology-driven filing.

Why the form is important

This form is important because it is the first step for many charitable and religious organisations that want formal tax recognition. It is also relevant for entities seeking approval so that donors can claim deduction on eligible donations. The department has indicated that more than 1.2 lakh applications are filed every year through this route which explains why simplification of this form matters.

What Form No. 104 is used for

Form No. 104 is used for two purposes:

• Provisional registration under Section 332(3) for eligible NPOs whose activities have not commenced.
• Provisional approval under Section 354(2) so that donations can qualify for deduction under Section 133(1)(b)(ii).

The form gives three section code choices:

• 01 – provisionalregistration
• 02 – provisional approval
• 03 – both registration and approval

Who can file it

The form is meant mainly for two groups:

• New nonprofit entities such as public trusts, societies, section 8 companies, and similar eligible bodies whose activities have not yet commenced.
• Registered nonprofit organisations or specified funds seeking provisional approval so that public donations become tax-deductible in the hands of donors.

The user manual states that all registered users on the e-Filing portal, except individual users, can use Form No. 104.

Key conditions to keep in mind

Before filing, applicants must check some basic conditions:

• The form applies only where activities have not commenced. If activities have already started, the correct form is Form No. 105.
• The trust must be irrevocable. A revocable trust cannot seek provisional registration or approval through this form.
• The applicant must have an active PAN and be a registered user on the e-Filing portal.

Structure of the form

The form is designed in a simple, panel-based format. It has four parts:

• Part A: Particulars of the Applicant
• Part B: Other Information
• Attachments
• Undertaking

Part A includes

• Name
• Address
• Pan
• Email ID
• Contact Number

Part B includes

• whether activities have commenced,
• whether the trust is irrevocable,
• whether any earlier application was rejected,
• whether religious expenditure exceeded 5% of total income,
• incorporation and constitution details,
• objects of the organisation,
• registration under other laws,
• office bearers and beneficial ownership,
• return filing status.

The form asks only for essential information and avoids unnecessary disclosures. That is one of its main compliance benefits.

Documents to be uploaded

The required documents are simple and self-certified. They generally include:

• trust deed or instrument of creation,
• registration certificate with ROC, Registrar of Societies, or Public Trust authority,
• FCRA registration, if applicable,
• copies of earlier rejection or cancellation orders, if any,
• annual accounts for up to three preceding years where returns were not filed,
• a brief or detailed note on proposed activities.

If audited annual accounts are not available, the form permits a self-certified NIL declaration for the relevant year.

Main simplifications in the new form

According to the department, the new form has been simplified in important ways:

• shorter and less complex format,
• removal of asset and liability details from the main form,
• removal of detailed income break-up,
• removal of extra religious expenditure disclosures from the main form,
• cleaner layout,
• greater use of pre-filled information.

These changes are especially useful for small and first-time NPO applicants.

How the filing process works

The filing is completely online through the e-Filing portal. The broad steps are:

• log in to the portal,
• go to e-File > Income Tax Forms > File Income Tax Forms,
• select forms under the Income Tax Act, 2025,
• choose Form No. 104,
• fill all four panels,
• preview the form,
• verify it through EVC or DSC.

After successful filing:

• a Transaction ID and Acknowledgement Receipt Number are generated,
• the filed form and attachments can be downloaded,
• the department later issues Form No. 106 with a 16-digit Unique Registration Number (URN) confirming provisional registration or approval.

Validity and withdrawal

A few practical points are worth noting:

• The application can be filed at any time during the relevant tax year.
• Once granted, provisional registration or approval remains valid for three tax years from the year of application.
• If the applicant makes a mistake, Form No. 104 can be withdrawn within 7 days of filing.

Conclusion

Form No. 104 is a practical attempt to simplify the NPO registration process. It reduces the initial compliance burden, keeps the filing digital, and focuses only on essential details needed for provisional entry into the tax system. For charitable and religious institutions that have not yet commenced activities, it offers a clearer and easier route to registration or approval. In that sense, it is not just a new form number, but a more streamlined compliance gateway for the nonprofit sector.

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