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Can a Charitable Trust, NGO, Society or Section 8 Company Lose Income-Tax Exemption? Section 13 and Forfeiture of Exemption

A charitable or religious trust, society, NGO or Section 8 company does not enjoy an unconditional exemption merely because it has obtained registration under the Income-tax Act.

The exemption available under Sections 11 and 12 of the Income-tax Act, 1961 is subject to several statutory conditions. Section 13 specifies circumstances in which the benefit of Sections 11 and 12 is denied, wholly or partly, in respect of income covered by the relevant violation.

Accordingly, it is more accurate to say that an organisation can lose the benefit of exemption in respect of specified income, rather than stating that every violation automatically forfeits the entire exemption of the institution.

Recent amendments have also introduced specific consequences for certain violations, including taxation under Section 115BBI, penalty provisions and, in specified cases, cancellation of registration.

 

What is Section 13 of the Income-tax Act?

Section 13 is titled "Section 11 not to apply in certain cases."

It identifies circumstances in which the exemption otherwise available under Sections 11 and 12 will not operate.

The principal situations include:

1. income from property held under a private religious trust which does not benefit the public;
2. a charitable trust or institution established for the benefit of a particular religious community or caste, subject to statutory exceptions;
3. income or property used for the benefit of specified related persons;
4. investments or deposits made otherwise than in the modes prescribed under Section 11(5); and
5. other specified violations covered by the statutory provisions.

 

1. Private Religious Trust Not Benefiting the Public

Under Section 13(1)(a), Section 11 does not apply to income from property held under a trust for private religious purposes where the trust does not enure for the benefit of the public.

Therefore, a private religious arrangement that does not benefit the public cannot claim the normal Section 11 exemption merely by describing itself as religious.

 

2. Trust for the Benefit of a Particular Religious Community or Caste

Under Section 13(1)(b), a charitable trust or institution created or established after commencement of the Income-tax Act, 1961 for the benefit of a particular religious community or caste is subject to denial of the Section 11 benefit in respect of the relevant income.

However, there is an important statutory exception.

A trust or institution established for the benefit of:

Scheduled Castes;
Scheduled Tribes;
backward classes;
women; or
children

is not treated as being established for the benefit of a particular religious community or caste merely because it benefits those groups.

Therefore, the old statement that every institution benefiting a particular group automatically loses exemption is too broad.

 

3. Benefit to Specified Persons Section 13(1)(c)

One of the most important provisions concerns the use of income or property of a charitable or religious institution for the direct or indirect benefit of persons specified in Section 13(3).

These persons broadly include:

the author of the trust;
founder of the institution;
a person who has made a substantial contribution;
relatives of such persons;
trustees or managers;
certain relatives of trustees/managers;
concerns in which specified persons have substantial interest; and
other persons covered by Section 13(3).

The exact definition and statutory conditions must be examined in each case.

If trust income or property is used or applied, directly or indirectly, for the benefit of a specified person, the exemption can be denied to the extent provided by Section 13.

Examples of Benefit to Interested Persons
Potential Section 13 issues can arise where a trust:

gives an interest-free loan to a trustee;
provides trust property to a trustee or related person for personal use;
pays excessive salary or remuneration to a specified person;
allows a related party to use trust assets without adequate consideration;
purchases property from a specified person at an excessive price;
sells trust property to a specified person for inadequate consideration; or
otherwise applies trust income or property for the private benefit of a specified person.

Not every transaction with a trustee or related person is automatically prohibited. The statutory provisions and applicable exceptions must be examined, including whether the transaction is at adequate consideration and falls within an exception under Section 13.

 

4. Investment in Violation of Section 11(5)

A charitable or religious trust must generally invest or deposit its funds only in the forms and modes specified under Section 11(5).

Section 13 contains provisions denying exemption where funds are invested or deposited in prohibited modes.

Examples may include investments that do not satisfy the statutory requirements of Section 11(5).

However, the provision contains several specific exceptions and qualifications. Therefore, each investment should be examined against the actual wording of Section 11(5) and Section 13 rather than applying a blanket rule.

 

5. Business Activities and Charitable Institutions

A charitable institution may carry on certain business activities, but the Income-tax Act imposes conditions.

Under Section 11(4A), income from a business undertaking held under trust can qualify for the statutory treatment where the business is incidental to the attainment of the objectives of the trust or institution and separate books of account are maintained in respect of the business.

Therefore, the mere existence of business receipts does not automatically result in forfeiture of exemption.

The nature of the activity, its connection with the charitable objects and compliance with the applicable accounting requirements are important.

The Income Tax Department also identifies non-incidental business activity and failure to maintain separate books as significant compliance issues for charitable institutions.

 

6. Application of Income for Non-Charitable Purposes

A trust registered for charitable purposes must apply its income in accordance with its charitable objects and the conditions of Sections 11 and 12.

If income is applied for purposes outside the permitted charitable/religious objects, the relevant exemption may be denied.

The Income Tax Department's current guidance identifies application of income for purposes other than the objects of the trust or institution as a specified violation in the relevant circumstances.

Is the Entire Exemption Forfeited?
Not necessarily.

This is an important correction to the wording commonly found in older articles.

Section 13 does not mean that every violation automatically makes the entire income of the trust taxable.

In several situations, the law provides for denial of exemption to the relevant part of the income or for taxation under specific provisions.

For example, where income or property is used for the benefit of a specified person, the consequences depend upon the particular provision and amount involved.

Therefore, the correct approach is:

Identify the specific violation -> determine the income/property affected -> apply the relevant charging or denial provision.

 

Section 115BBI Tax on Specified Income of Certain Trusts

A major development after the original publication of this article is the introduction of Section 115BBI.

Section 115BBI provides for taxation of specified income of certain trusts and institutions at the maximum marginal rate, subject to the statutory provisions.

The Income Tax Department's current guidance specifically states that where a trust or institution passes on benefits to related persons, the relevant amount is taxable under Section 115BBI.

Thus, an article stating simply that the Assessing Officer "forfeits exemption" is incomplete under the present law.

The consequences may include:

denial of exemption for relevant income;
taxation under Section 115BBI;
interest and other tax consequences;
penalty in specified circumstances; and
cancellation of registration in cases involving specified violations.

 

Penalty Under Section 271AAE

The Finance Act introduced a specific penalty provision for certain benefits provided by a trust or institution to specified persons.

Under Section 271AAE, penalty consequences can arise in specified cases involving benefits provided to persons referred to in Section 13(3).

The Income Tax Department's current publication states that this penalty provision applies from Assessment Year 2023-24.

Therefore, trustees and governing-body members should exercise particular care before providing loans, benefits, facilities or other advantages to related persons.

 

Cancellation of Registration for Specified Violations

The consequences of non-compliance can extend beyond taxation of a particular amount.

Under the current Section 12AB framework, a trust or institution can face cancellation of its registration in specified circumstances.

The Income Tax Department identifies the following among the circumstances that can constitute a "specified violation":

application of income for purposes other than the institution's objects;
non-incidental business activity or failure to maintain separate books;
application of income for private religious purposes;
application for the benefit of a particular religious community or caste;
activities that are not genuine;
false or incorrect information in the registration application; and
violation of other applicable laws.

Consequently, Section 13 compliance is now closely connected with the continued validity of Section 12AB registration.

 

Tax on Accreted Income Section 115TD

Cancellation or other specified cessation of charitable registration can also have a separate consequence under Section 115TD.

In specified circumstances, tax may be imposed on the accreted income of the trust or institution.

This provision is particularly important where an organisation:

ceases to be eligible for registration;
merges in circumstances not satisfying the prescribed conditions;
converts into a non-charitable form; or
is dissolved without transferring its assets in the manner required by law.

Accordingly, an organisation should obtain professional advice before changing its legal structure or dissolving.

 

Important Compliance Requirements

To avoid loss of exemption or other adverse consequences, a charitable institution should ensure that:

1. Its activities remain within its objects
Activities should genuinely correspond with the objects contained in its trust deed, memorandum or other constitutional document.

2. Trust property is not used for private benefit
Trust property should not be used for personal purposes of trustees, founders or related persons except where specifically permitted by law.

3. Related-party transactions are properly documented
Any transaction involving trustees or specified persons should be examined for compliance with Section 13 and the applicable exceptions.

4. Investments comply with Section 11(5)
All investments and deposits should be reviewed periodically.

5. Separate books are maintained for incidental business
Where the institution carries on a permitted incidental business, separate books should be maintained as required.

6. Books of account are maintained under Rule 17AA
The current law prescribes books and documents to be maintained by charitable or religious trusts and institutions.

7. Audit requirements are followed
Where the statutory audit requirement applies, the prescribed audit report should be obtained and furnished within the prescribed time.

8. Income-tax return is filed on time
Timely filing is an important condition for continuing to claim the applicable exemption.

9. Donation reporting is completed
Where applicable, the institution must furnish the prescribed statement of donations, including Form 10BD, and issue the corresponding Form 10BE to donors.

The Income Tax Department's current guidance expressly lists Form 10BD among the annual compliance requirements of charitable institutions.

Can an NGO or Section 8 Company Lose Its Tax Exemption?
Yes.

The legal form of the organisation does not provide immunity from Section 13.

A:
charitable trust;
society;
NGO;
Section 8 company; or
other eligible charitable institution

must comply with the applicable Income-tax provisions if it is claiming exemption under Sections 11 and 12.

The old terminology "Section 25 company" should now generally be replaced with "Section 8 company" when referring to companies incorporated under the Companies Act, 2013.

Practical Examples
Example 1
Personal use of Trust Property
A charitable trust owns a residential property.

A trustee uses the property for his personal residence without satisfying the applicable statutory conditions.

This may constitute a benefit to a specified person and can trigger consequences under Section 13.

The exact tax consequence depends upon the facts, amount involved and applicable statutory provisions.

Example 2 Prohibited Investment
A trust invests its funds in a mode that does not qualify under Section 11(5).

The investment should be reviewed immediately because Section 13 contains provisions denying exemption in respect of income associated with prohibited investments, subject to statutory exceptions.

Example 3 Incidental Business
A charitable educational institution operates a canteen for students as an activity incidental to its charitable objects and maintains separate books as required.

The mere fact that the institution receives business income does not automatically mean that its charitable exemption is forfeited.

Example 4 Private Benefit
A trust provides an interest-free personal loan from trust funds to a trustee.

This is a high-risk transaction under Section 13 and should not be undertaken without examining the statutory provisions and applicable exceptions.

 

Section 13 Compliance Checklist

A charitable institution should periodically verify:

[ ] Objects are genuinely charitable/religious.
[ ] Activities are consistent with the registered objects.
[ ] No trust income/property is improperly used for specified persons.
[ ] Trustee remuneration is properly authorised and reasonable.
[ ] Related-party transactions are documented.
[ ] Investments comply with Section 11(5).
[ ] Incidental business has separate books.
[ ] Books are maintained under Rule 17AA.
[ ] Income-tax return is filed within the prescribed time.
[ ] Audit report is furnished where required.
[ ] Accumulation requirements are complied with.
[ ] Form 10 is filed wherever required.
[ ] Donation statements are correctly reported.
[ ] Form 10BD is filed within the prescribed time.
[ ] Form 10BE is issued to donors.
[ ] Section 12AB registration remains valid.
[ ] Changes in objects are dealt with under the applicable registration provisions.
[ ] No false or misleading information is furnished to the Income-tax Department.
[ ] Compliance with other applicable laws is maintained.

Conclusion
Section 13 is an important anti-abuse provision applicable to charitable and religious institutions claiming exemption under Sections 11 and 12.

The old description that an Assessing Officer simply "forfeits the exemption" of an NGO, trust, society or company whenever Section 13 is violated is too broad under the present law.

Depending upon the nature of the violation, the consequences can include:

1. denial of exemption in respect of specified income;
2. taxation of specified income under Section 115BBI;
3. penalty under Section 271AAE in specified cases;
4. cancellation of Section 12AB registration for a specified violation; and
5. tax on accreted income under Section 115TD in applicable cases.

Therefore, charitable institutions should maintain strict controls over related-party transactions, investments, application of income, business activities, accounts, audit, return filing and statutory reporting.

Important: This article explains the Section 13 framework under the Income-tax Act, 1961, particularly for earlier assessment years and transitional matters. The Income-tax Act, 2025 applies from 1 April 2026 for tax years governed by that Act, and the corresponding provisions should be checked for transactions and tax years falling under the new law.

This article is for general information and should not be treated as legal or tax advice for a particular trust or institution. The precise tax consequence of a Section 13 issue depends on the facts, relevant assessment year and applicable statutory provisions.
 

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