Form 10BD Missed Filing and Correction Guide Revised-10BD, Omitted Donors, 80G Donation Limit and Form 10B/10BB Reporting
1. Introduction
Form 10BD is an important annual compliance requirement for trusts, institutions, NGOs and other approved entities receiving donations eligible for deduction under section 80G or section 35 of the Income-tax Act, 1961. Under the Income-tax Act, 2025, the corresponding provisions are section 133 read with section 354 for approved donation reporting and section 45 for scientific research-related provisions.
| In this article, I have discussed the practical applicability, reporting requirements, correction procedure, monetary-limit position, audit-report reconciliation and key precautions relating to Form 10BD, Form 10BE, Revised Form 10BD and Form 10B / Form 10BB reporting. In case you have any doubt after reading this article, or if you feel that any practical aspect requires further discussion, you may contact me at the contact details mentioned at the end of this article. |
Filing of Form 10BD enables generation of Form 10BE, which is the donation certificate required by the donor for claiming deduction. Under the Income-tax Act, 2025 framework, Form 10BD and Form 10BE are mapped to Form 113 and Form 114 respectively.
In practice, many institutions face issues such as delayed filing, non-filing, wrong donor details, omitted donors, mismatch between books and Form 10BD, or confusion regarding whether small donations are required to be reported. These issues become more important at the time of filing the audit report in Form 10B or Form 10BB, because the audit form requires reconciliation of donations reported in Form 10BD with total voluntary contributions as per books.
This article discusses the practical approach for managing missed Form 10BD filing, correction of wrong data, addition of omitted donors, monetary-limit misconceptions, and alignment with Form 10B / Form 10BB.
2. Applicability of Form 10BD
Form 10BD is applicable to a trust, institution, fund, NGO or other reporting entity approved under section 80G or section 35 of the Income-tax Act, 1961, where donation is received during the relevant financial year.
Under the Income-tax Act, 2025, the corresponding framework is not under the same section numbers. Deduction for donations is covered under section 133, approval and reporting obligations of eligible institutions are covered under section 354, and scientific research-related provisions are covered under section 45.
If no donation is received during the financial year, Form 10BD is generally not required. However, where donation has been received and the institution is under an obligation to report donor-wise details, Form 10BD should be filed.
The statement is filed by the donee institution and contains particulars of donations received from donors. After filing Form 10BD, the institution is required to issue Form 10BE to the donors.
3. Due Date for Form 10BD and Form 10BE
Form 10BD is required to be filed by 31st May immediately following the financial year in which the donation is received.
Form 10BE is also required to be issued to donors by the same date.
Under the Income-tax Act, 2025 framework, Form 113 and Form 114 are the corresponding forms for statement / correction statement and certificate of donation.
Example
For donations received during FY 2025-26, the due date for filing Form 10BD and issuing Form 10BE is 31.05.2026.
4. Consequences of Late Filing or Non-Filing
Failure to file Form 10BD within the prescribed time may result in late fee and penalty exposure.
| Default | Consequence |
| Delay in filing Form 10BD | Late fee under section 234G of the Income-tax Act, 1961 |
| Delay in issuing Form 10BE | Late fee exposure under section 234G of the Income-tax Act, 1961 |
| Non-filing or continued default | Penalty under section 271K of the Income-tax Act, 1961 |
| Donor-wise data not reported | Donor’s deduction may not reflect properly |
Under the Income-tax Act, 2025, the corresponding late fee provision is section 429, and the corresponding penalty provision is section 464.
Late Fee under Section 234G / Section 429
If Form 10BD is filed after the due date, late fee under section 234G of the Income-tax Act, 1961 may be payable at ₹200 per day for the period of default. The late fee cannot exceed the amount of donation in respect of which default has occurred.
Under the Income-tax Act, 2025, the corresponding provision is section 429, which provides for fee for default relating to statement or certificate.
Penalty under Section 271K / Section 464
In addition to late fee under section 234G, penalty under section 271K of the Income-tax Act, 1961 may also be levied. The penalty may range from ₹10,000 to ₹1,00,000 for failure to furnish the required statement or certificate.
Under the Income-tax Act, 2025, the corresponding provision is section 464, which provides for penalty for failure to furnish statements, etc.
Therefore, if Form 10BD has been missed, the better approach is to file it immediately, pay applicable late fee, issue Form 10BE and maintain proper documentation explaining the delay.
5. Practical Steps Where Form 10BD Filing Is Missed
Where Form 10BD was not filed within the due date, the institution should take the following steps:
| Step | Action |
| 1 | Confirm applicability of Form 10BD for the relevant financial year |
| 2 | Prepare and reconcile donor-wise donation data with books, bank, cash book and receipt records |
| 3 | Verify section 80G / section 35 approval validity under the Income-tax Act, 1961 or corresponding approval under the Income-tax Act, 2025, wherever applicable |
| 4 | File Form 10BD immediately and pay late fee under section 234G, if applicable |
| 5 | Download Form 10BE, issue it to donors and preserve filing records with delay explanation |
The institution should maintain a proper compliance file containing donor list, donation ledger, receipt copies, bank statement, Form 10BD acknowledgement, late-fee challan, Form 10BE copies and management note explaining the delay.
6. Correction of Incorrect Data in Form 10BD
If Form 10BD has already been filed but the data is incorrect, the error can be corrected by filing a Revised Form 10BD.
Under the Income-tax Act, 2025 framework, the corresponding form is Form 113, which covers statement or correction statement by the donee.
Revised Form 10BD may be required in cases such as wrong donor name, wrong PAN / Aadhaar / identification number, wrong address, wrong amount, wrong donation date, wrong donation mode or duplicate entry.
| Mistake | Corrective Action |
| Wrong donor name | Revise donor details |
| Wrong PAN / Aadhaar / ID details | File revised details |
| Wrong donation amount | Correct amount in Revised Form 10BD |
| Wrong address | Revise / add correct address |
| Duplicate entry | Mark duplicate entry for deletion |
| Wrong donation date / mode / type | Revise the relevant particulars |
| Donor omitted earlier | Add the missed donor in Revised Form 10BD |
| Donation wrongly reported | Delete or revise the incorrect entry |
The correction should be supported by books of account, donation receipts, bank statement, cash book and donor identification records.
7. Addition of Omitted Donors in Revised Form 10BD
If some donors were not added in the original Form 10BD, they can be added through Revised Form 10BD, provided the donation was actually received during that financial year and proper records are available.
| Situation | Treatment |
| Donor completely missed in original Form 10BD | Add the donor in Revised Form 10BD |
| Wrong donor details reported | Revise the donor entry |
| Duplicate donor entry | Delete duplicate entry |
| Donation amount wrongly reported | Correct the amount and issue revised Form 10BE |
| Donation not actually received | Do not add merely to give deduction benefit |
Under the Income-tax Act, 2025 framework, section 354(1)(f) contemplates correction statement for rectification of mistake or to add, delete or update information furnished in the statement.
Before adding any omitted donor, the institution should verify that the donation was actually received, recorded in books and supported by receipt / banking record.
8. Portal Process for Revised Form 10BD
The revised filing process is broadly as follows:
1. Login to the income-tax portal.
2. Go to e-File → Income Tax Forms → Form 10BD.
3. Select the relevant financial year.
4. Choose Filing Type: Revised.
5. Download / export the existing donor data or revised template.
6. Make corrections in the CSV / template.
7. Mark the relevant entry as Revised or Delete, wherever applicable.
8. Add omitted donor details, if any.
9. Upload the revised CSV / template.
10. Submit and e-verify the revised Form 10BD.
11. After processing, download revised Form 10BE.
12. Issue revised / corrected Form 10BE to the concerned donors.
Under the Income-tax Act, 2025 framework, the corresponding forms are Form 113 and Form 114.
Where correction affects a donor’s deduction claim, the donor should also be informed so that he can verify the updated details in his income-tax records.
9. Is There Any Monetary Limit for Form 10BD Reporting?
There is no minimum monetary limit prescribed for reporting in Form 10BD where the donation is otherwise reportable and donor-wise details are available.
A small donation of ₹100, ₹500 or ₹1,000 is not outside Form 10BD merely because the amount is small.
| Point | Position |
| Small donation | Reportable, if donor-wise reporting is applicable |
| Donation below ₹2,000 | Not exempt from Form 10BD merely due to small amount |
| Maximum reporting amount | No separate maximum limit for Form 10BD reporting |
| ₹2,000 limit | Relevant only for cash donation deduction restriction under section 80G(5D) of the Income-tax Act, 1961 |
| Corresponding 2025 Act reference | Section 133 contains the corresponding deduction framework under the Income-tax Act, 2025 |
| Pre-ARN limit of 1,000 | Portal facility count, not monetary limit |
The common confusion is regarding the ₹2,000 cash limit. This limit does not mean that donations below ₹2,000 need not be reported in Form 10BD. It only means that where donation exceeds ₹2,000 and is made in cash, the donor is not eligible for deduction under section 80G of the Income-tax Act, 1961. Under the Income-tax Act, 2025, the corresponding deduction framework is under section 133.
Practical Examples
| Example | Treatment |
| Donation of ₹500 by bank | Reportable, if donor-wise certificate is to be issued |
| Donation of ₹1,500 in cash | Can be reported, subject to other eligibility conditions |
| Donation of ₹5,000 by cheque / UPI / bank | Reportable |
| Donation of ₹5,000 in cash | Donor’s deduction is restricted due to cash-donation restriction |
| Donation box collection without donor details | Do not fabricate donor details; examine anonymous donation treatment |
Thus, no artificial cut-off such as ₹2,000, ₹5,000 or ₹10,000 should be applied for Form 10BD reporting.
10. Treatment of Anonymous Donations
If donor identity is not available, the amount should not be blindly shown as a normal 10BD donation.
Section 115BBC of the Income-tax Act, 1961 deals with anonymous donations. Broadly, anonymous donation means a voluntary contribution where the recipient does not maintain record of the identity of the donor, including name, address and other prescribed particulars.
Under the Income-tax Act, 2025, the corresponding treatment is not under section 115BBC. Anonymous donation is dealt with through section 337, read with the definition in section 355(a).
Anonymous donations may be taxable at 30% on the amount exceeding the higher of:
1. 5% of total donations received; or
2. ₹1,00,000.
This is subject to statutory exceptions.
Therefore, where donor details are not available, the institution should examine whether the amount is to be classified as anonymous donation, donation not reportable in Form 10BD due to non-availability of donor identification, or any other voluntary contribution.
11. Form 10BD and Audit Report Disclosure
Form 10BD figures must be aligned with the income-tax audit report of the trust / institution. This reporting is made in Form 10B or Form 10BB, as applicable, under the Income-tax Act, 1961 framework. It is not normally a disclosure item in business tax audit Form 3CD.
Under the Income-tax Act, 2025 framework, Form 10B / Form 10BB are mapped to Form 112, being the audit report under section 348 in the case of a registered non-profit organisation.
The audit report requires reconciliation between:
1. total donation / voluntary contribution as per books;
2. donation reported in Form 10BD;
3. donations not reported or not required to be reported in Form 10BD; and
4. total voluntary contribution reported in the audit form.
12. Reporting in Form 10B and Form 10BB
The relevant reporting in Form 10B and Form 10BB is under the broad head of voluntary contributions. The reporting structure may be compared as follows:
| S. No. | Form 10B | Form 10BB |
| 1 | Sr. 21 — Whether auditee has filed Form 10BD for the previous year | Sr. 12 — Whether auditee has filed Form 10BD for the previous year |
| 2 | Sr. 22 — Total sum of donations reported in Form 10BD | Sr. 13 — Sum total of donations reported in Form 10BD |
| 3 | Sr. 23 — Donations not reported in Form 10BD / not required to be reported | Sr. 14 — Donations not reported in Form 10BD / not required to file Form 10BD |
| 4 | Sr. 24 — Total voluntary contributions received during the previous year | Sr. 15 — Total voluntary contributions received during the previous year |
| 5 | Sr. 25 — Total foreign contribution out of total voluntary contributions | Sr. 16 — Total foreign contribution out of total voluntary contributions |
| 6 | Sr. 26 — Voluntary contribution forming part of corpus | Sr. 17 — Voluntary contribution forming part of corpus |
| 7 | Anonymous donation to be examined and reported in the relevant applicable clause, wherever applicable | Sr. 18 — Anonymous donations taxable at 30% under section 115BBC |
Under the Income-tax Act, 2025 framework, Form 10B / Form 10BB are mapped to Form 112. Therefore, while filing under the 2025 Act framework, the relevant form reference should be checked as Form 112 under section 348.
The important reconciliation is:
| For Form 10B
Total voluntary contributions as per Sr. 24 = Donation reported in Form 10BD as per Sr. 22 + Donation not reported / not required to be reported as per Sr. 23(viii). |
–
| For Form 10BB
Total voluntary contributions as per Sr. 15 = Donation reported in Form 10BD as per Sr. 13 + Donations not reported / not required to be reported as per Sr. 14. |
Thus, the audit form does not merely ask whether Form 10BD was filed. It also requires numerical reconciliation with total voluntary contributions.
13. Which Audit Form Applies: Form 10B or Form 10BB?
Form 10B or Form 10BB is selected as per the applicable rules and conditions for charitable or religious trusts / institutions under the Income-tax Act, 1961.
Broadly, Form 10B applies in cases involving higher compliance conditions such as:
1. total income before exemption exceeding the prescribed threshold;
2. receipt of foreign contribution; or
3. application of income outside India.
In other eligible cases, Form 10BB is generally applicable.
Under the Income-tax Act, 2025 framework, the corresponding audit form is Form 112 under section 348. Therefore, the institution and auditor should confirm the applicable form with reference to the applicable Act and assessment year / tax year before filing.
14. Core Reconciliation Between Books, Form 10BD and Audit Report
Before filing Form 10B or Form 10BB, the auditor should prepare a reconciliation of donations.
Basic Formula
| Reconciliation Formula
Total voluntary contributions as per books = Donations reported in Form 10BD + Donations not reported / not required to be reported in Form 10BD |
Practical Reconciliation Format
| Particulars | Amount |
| Total donations / voluntary contributions as per Income & Expenditure Account | |
| Add: Corpus donations directly credited to corpus fund, if not routed through Income & Expenditure Account | |
| Add: Specific grants / project donations treated separately in books | |
| Add: Foreign contribution, if any | |
| Less: Amount wrongly credited as donation but actually fee / sale / reimbursement | |
| Total voluntary contributions for audit reporting | |
| Less: Donations reported in Form 10BD | |
| Balance donations not reported / not required to be reported in Form 10BD |
The balance amount should be properly classified and reported in Form 10B Sr. 23 or Form 10BB Sr. 14, as applicable.
Under the Income-tax Act, 2025 framework, the same reconciliation logic should be aligned with Form 112 and the statement / certificate framework in Form 113 / Form 114.
15. Income-tax Act, 2025 Position
The Income-tax Act, 2025 does not retain the same section numbers for these provisions. Therefore, references should be used carefully.
The broad corresponding references are:
| Subject | Income-tax Act, 1961 | Income-tax Act, 2025 |
| Deduction for donations | Section 80G | Section 133 |
| Approval / reporting by eligible donee institution | Section 80G(5) and related provisions | Section 354 |
| Scientific research | Section 35 | Section 45 |
| Statement of donation | Form 10BD | Form 113 |
| Certificate of donation | Form 10BE | Form 114 |
| Audit report for trust / institution | Form 10B / Form 10BB | Form 112 |
| Audit provision | Sections 12A / related trust audit framework | Section 348 |
| Late fee for statement / certificate default | Section 234G | Section 429 |
| Penalty for failure to furnish statement / certificate | Section 271K | Section 464 |
| Anonymous donations | Section 115BBC | Section 337 read with section 355(a) |
Accordingly, where the article is used for present compliance under the Income-tax Act, 1961, references to section 80G, section 35, section 234G, section 271K and section 115BBC may be retained. However, where the article is updated for the Income-tax Act, 2025 framework, the corresponding provisions should be separately mentioned as stated above.
16. Final Practical Conclusion
Form 10BD is not merely a portal filing requirement. It directly affects donor deduction, Form 10BE generation and audit report reporting.
The correct professional approach is:
1. Take total donation / voluntary contribution as per books.
2. Match it with donor-wise Form 10BD total.
3. Identify donations not reported or not required to be reported in Form 10BD.
4. File Revised Form 10BD where identifiable donors were missed or details were wrong.
5. Do not apply any artificial monetary limit for Form 10BD reporting.
6. Treat ₹2,000 only as the cash-donation deduction restriction under section 80G(5D) of the Income-tax Act, 1961, with corresponding deduction framework under section 133 of the Income-tax Act, 2025.
7. Separately examine anonymous donations under section 115BBC of the Income-tax Act, 1961, or section 337 read with section 355(a) of the Income-tax Act, 2025, as applicable.
8. Align Form 10BD, Form 10BE and Form 10B / Form 10BB under the 1961 Act framework, or Form 113, Form 114 and Form 112 under the 2025 Act framework, as applicable.
9. Maintain complete reconciliation and supporting records.
10. If there is an unresolved mismatch, disclose or qualify appropriately in the audit report.
A properly reconciled Form 10BD filing protects the institution, supports donor deduction claims and ensures consistency in audit and return filing.
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