With the introduction of the Income-tax Act, 2025, a major shift has taken place in how non-profit organisations (NPOs) begin their tax registration journey. Effective from 1 April 2026, Form 104 has become the new standard for provisional registration and approval replacing the earlier Form 10A in this initial stage.
This change is designed to make the process simpler, faster, and more structured for newly formed organisations that have not yet started their activities.
What is Form 104?
Form 104 is a digital application form used by eligible NPOs to obtain:
- Provisional registration under Section 332
- Provisional approval under Section 354 (for donation deductions)
It is important to understand that this form is meant only for organisations that have not commenced activities yet. If activities have already started, a different form (Form 105) must be used.
Key Features and Improvements
The new Form 104 brings several practical improvements:
- Shorter and simpler – Reduced to a concise structure with fewer fields
- Auto-filled data – Pulls basic details like PAN and profile info
- Fewer attachments – Documents required only in specific cases
- Fully online process – Filed through the income tax e-filing portal
- Faster processing – Decision expected within 1 month
These updates reduce compliance burden and make it easier for new NPOs to enter the system.
Who Can Apply?
Form 104 is applicable only if:
- The organisation is new or not yet operational
- Activities have not commenced
- The entity is eligible under the new law
- It is not a revocable trust
This makes it a starting-point form, not a universal application for all NGOs.
Documents Required
Unlike older processes, documents are now conditional, not mandatory in every case. Common requirements include:
- Trust deed or incorporation proof
- Registration certificates (if applicable)
- FCRA certificate (if available)
- Note on proposed activities
Annual accounts are required only if certain conditions apply, such as non-filing of previous returns .
Processing and Validity
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Filed electronically with DSC or EVC verification
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Processed by CPC (Central Processing Centre)
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Approval issued via Form 106 with a URN (Unique Registration Number)
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Valid for:
- 3 years, or
- 6 months after activities begin (whichever is earlier)
Important Cautions
- Filing Form 104 after starting activities will make the application invalid
- Incorrect or false information can lead to cancellation
- It is strictly for provisional status, not final registration
Conclusion
Form 104 marks a clear move toward digitised, efficient, and streamlined compliance for India’s non-profit sector. While it simplifies the entry process, it does not dilute eligibility requirements. For new NPOs, it offers a clean and structured way to begin their regulatory journey but only if used correctly.
Understanding when and how to use Form 104 is key. If applied properly, it can save time, reduce paperwork, and ensure faster approvals in the evolving tax framework of 2026.