A registered public trust in Maharashtra runs two compliance cycles at once, under two different authorities, on two different calendars. Most trusts track one and are surprised by the other. This page sets both out in one place.
Position as at September 2026. Deadlines in the income tax track are frequently extended and the framework itself changed on 1 April 2026, so dates should be confirmed each year rather than carried forward.
Track one: the Charity Commissioner
This cycle runs off the Maharashtra Public Trusts Act, 1950 and the Rules made under it, and it keys off the date the trust balances its accounts rather than off a fixed calendar date.
| Step | When | What is filed |
|---|---|---|
| Balance the accounts | End of the trust’s accounting year | Internal — but it starts the clock for everything below |
| Audit | Within six months of the date of balancing | Audit conducted by a qualified auditor |
| File the audited statements | Within a fortnight of the audit | Schedule VIII (balance sheet), Schedule IX (income and expenditure), Schedule IX-C (income liable to contribution), Schedule IX-D (auditor’s further particulars) |
| Change reports | Within 90 days of each change | Schedule III, with supporting documents |
| Section 36 sanction | Before the trust commits itself | Application for previous sanction to sell, exchange, gift or grant a long lease |
Two things about this track that trusts get wrong. The filing deadline is not a fixed date in the year — it is six months plus a fortnight from whenever the trust balanced, so a trust that balances late pushes everything downstream. And change reports are not annual: the ninety days runs from each individual change, so a trust with four changes in a year has four separate clocks. See public trust compliance.
Schedule IX-D, added by the 2019 amendment rules, is worth flagging because it catches trusts out. It requires the auditor to report the trust’s PAN, its income tax registration particulars, income tax return acknowledgements for the preceding three years, and the PANs of all trustees. A trust that has not been filing income tax returns cannot complete it — which is how the two tracks collide.
Track two: income tax, and what changed on 1 April 2026
This is the part of the calendar that has been rewritten. The Income-tax Act, 2025 came into force on 1 April 2026 and consolidated the provisions for charitable and religious organisations into a single chapter, where they are dealt with as Registered Non-Profit Organisations.
The timing distinction matters more than anything else on this page:
- Income earned in the financial year 2025–26 continues to be governed by the Income-tax Act, 1961. Returns and audit reports filed during 2026 for that year use the old forms.
- Income earned from 1 April 2026 onwards falls under the 2025 Act, with new form numbers and a renumbered set of sections.
So a trust filing in late 2026 is working under the old regime for the year just gone, while already operating under the new one. Both need to be got right, and they are not the same.
What existing registrations are worth now
The most common question, and the reassuring answer: a trust already registered under Section 12A, 12AA or 12AB, or approved under Section 80G, of the 1961 Act does not have to re-register immediately. The transitional provisions treat existing registrations as continuing until they expire, and the organisation is treated as a registered non-profit under the new framework.
What that does not mean is that nothing needs doing. Registrations granted under the regime introduced a few years ago run for a fixed period and have to be renewed before expiry. A trust holding an old open-ended certificate from the 1990s is in a different and weaker position than it assumes. The practical step is to establish what the trust actually holds and until when, which is a five-minute check that a surprising number of boards have never done.
The shape of the annual income tax cycle
| Obligation | Roughly when | Note |
|---|---|---|
| Statement of donations received, and certificates to donors | After the end of the financial year | What allows donors to claim their deduction. Missing it damages the donors, not just the trust. |
| Audit report of the trust’s accounts | Before the return is due | Under the new Act the previously separate audit forms are consolidated into a single report. |
| Return of income | Ordinarily 31 October for a trust required to be audited | Extensions are common; confirm for the year in question. |
| Notices about accumulation or deemed application of income | On or before the return due date | Relevant where income has not been applied to the objects in the year. |
| Renewal of registration and approval | Before expiry of the current period | Do not leave to the last month. A lapse interrupts the trust’s exemption and its donors’ deductions. |
Form numbers under the new Act differ from those used under the 1961 Act, and the transition year is exactly when mistakes happen. This is accountancy work and should be done by the trust’s chartered accountant; what matters from the legal side is that the underlying position — who the trustees are, what the objects are, what the trust actually did with its income — is consistent with what the Charity Commissioner’s register says. See 12A, 80G and CSR-1.
Where the two tracks collide
Almost always in the same three places.
- Schedule IX-D asks for income tax particulars. A trust behind on returns cannot complete its Charity Commissioner filing properly.
- Income tax applications ask who the trustees are. If the change reports were never filed, the register names people who left years ago, and the person signing the tax application is not a recorded trustee.
- Funders ask for both. A CSR donor or a grant-making body wants the registration certificate, the current trustee list, and three years of audited accounts. A gap in either track stops the money.
A workable yearly routine
- Fix the accounting year and balance on time. Everything in track one dates from that.
- Book the audit early enough to leave room inside the six months.
- Report each change within ninety days as it happens, rather than saving them up.
- Check once a year what registrations the trust holds and when they expire.
- Keep the trust’s money where Section 35 permits.
- Before entering into anything concerning property, ask whether Section 36 sanction is needed — before signing, not after.
A board that does those six things is, in practice, compliant. A board that does none of them will be told so by a funder, a bank or a purchaser at the least convenient moment.
Common questions
When must a Maharashtra public trust file its audited accounts?
The Rules require the accounts to be audited within six months of the date of balancing, and the auditor to forward the balance sheet, income and expenditure account and audit report to the Deputy or Assistant Charity Commissioner within a fortnight of the audit. It is not a fixed calendar date — it runs from when the trust balances its accounts.
Which schedules does a trust file with the Charity Commissioner?
Schedule VIII for the balance sheet, Schedule IX for the income and expenditure account, and Schedule IX-C for the statement of income liable to contribution. The 2019 amendment rules added Schedule IX-D, in which the auditor reports the trust’s PAN, its income tax registration particulars, return acknowledgements for the preceding three years, and the PANs of all trustees.
Does my trust’s 12A or 80G registration still work after the Income-tax Act 2025?
Yes. The Act came into force on 1 April 2026, and organisations already registered under Section 12A, 12AA or 12AB, or approved under Section 80G, of the 1961 Act are treated as registered non-profit organisations under the new framework, with their existing registrations continuing until they expire. Registrations granted for a fixed period still have to be renewed before that period ends.
Which Act applies to income my trust earned in 2025-26?
The Income-tax Act, 1961. The 2025 Act applies to income earned from 1 April 2026 onwards. That means a trust filing during 2026 for the previous year works under the old Act and old forms, while already operating under the new one for the current year.
What is the deadline for a change report?
Ninety days from the date of the change, under Section 22 of the Maharashtra Public Trusts Act, 1950. The period runs separately from each change, so several changes in one year mean several separate deadlines — it is not an annual filing.
What happens if we miss the Charity Commissioner filing?
There is no immediate consequence, which is why it happens. The difficulty arrives when the trust next needs something — a property sanction, a grant, an income tax application — and the missing filings are raised before the merits are considered. Catching up means reconstructing and auditing the accounts year by year.
Discussing compliance
Consultations are at chambers at 704 Classic Building, Gate No. 8, Malwani MHADA, Malad (West), Mumbai 400095, by appointment, and a first discussion about a trust’s compliance position is usually held by telephone or WhatsApp. Telephone or message +91 99301 50560, or use the contact page.
Position as at September 2026. This page describes procedure in general terms and is not legal advice. Income tax deadlines are frequently extended and the framework changed on 1 April 2026; dates should be confirmed for the year in question. The income tax filings themselves are work for the trust’s chartered accountant.
See also: Renewing 12A and 80G under the Income-tax Act, 2025.
Related guides
- Trust ITR-7 for AY 2026-27: Due Dates and Form 10B/10BB
- Annual Accounts and Audit for a Public Trust in Maharashtra
All guides in one place: Charity Commissioner and public trusts
This page describes general procedure and is published for information only, in keeping with Rule 36 of the Bar Council of India Rules. It is not legal advice and does not solicit work. What applies to a particular matter depends on its own facts.