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Direct Tax10 October 20265 min read

Form 112 is real, and it is not this year's form

Search for the trust audit form and you will be told about Form 112. It replaces Forms 10B and 10BB — from next year. This year's report is due on the twenty-first.

In short
  • Income up to 31 March 2026 is assessed under the Income-tax Act, 1961, so the audit report for that year remains Form 10B or Form 10BB — not Form 112.
  • Form 112 is the unified audit report under section 348 of the Income-tax Act, 2025, replacing both older forms, and it applies from tax year 2026-27 onwards.
  • This year's audit report is due 21 October 2026 under CBDT Circular 07/2026, with the return in covered cases moving to 21 November 2026, and the report must precede the return.
A volunteer handing a plate of food across a serving counter, the work a registered non-profit exists to doPhotograph: Khalil Radi / Unsplash

A trust client's audit is due on 21 October, which is eleven days away, and the search results for "trust audit form" are full of Form 112.

Form 112 is real. It is also not this year's form, and the confusion is costing people time in the worst possible fortnight.

The year decides the form

Which report, which year

Start with the period being audited. It settles the form before any of the other questions matter.

Form 112 is the audit report under section 348 of the Income-tax Act, 2025, and it is not this year’s form: income up to 31 March 2026 is assessed under the 1961 Act and is reported on Form 10B or Form 10BB. Sources differ on the rule number governing Form 112 — some cite rule 186 of the Income-tax Rules, 2026 and others rule 188 — and on whether the foreign-contribution and applied-outside-India tests survive alongside the ₹5 crore threshold. Both are worth confirming against the notified rules rather than from commentary, including this.

Income up to 31 March 2026 belongs to the Income-tax Act, 1961. The audit report for it is Form 10B or Form 10BB, as it was last year.

Income from 1 April 2026 belongs to the Income-tax Act, 2025, and is reported on Form 112 — the unified audit report under section 348, which replaces both of the old forms with one.

So a trust being audited this month, for the year ended 31 March 2026, files Form 10B or 10BB. Form 112 is next year's problem, and it is a genuine one, but it is not this one.

Nothing about the form you file this October has changed. What has changed is how much material there now is on the internet telling you otherwise.

Choosing between 10B and 10BB this year

The heavier form, Form 10B, is indicated where the institution has total income above ₹5 crore before giving effect to the exemptions, where it has received any foreign contribution, or where any part of its income has been applied outside India. Otherwise Form 10BB.

A caution worth stating: sources do not all describe those three tests the same way. Some give only the ₹5 crore threshold. The consequence of choosing the lighter form wrongly is a defective report rather than a late one, which is the more awkward of the two problems to fix after the event, so this is a place to check the provision rather than a checklist.

The date

21 October 2026 for the audit report, extended by CBDT Circular 07/2026 from 30 September. For covered cases the return moves to 21 November 2026.

The report comes before the return, and for a trust the return is ITR-7. Filing the return without the report in place is the sequence error that produces a defect notice.

What Form 112 will actually change, next year

Worth a paragraph now because the planning happens this year.

One form instead of two. The 10B / 10BB split, and the tests that decide between them, go. That removes an annual judgement call that has produced a steady stream of defective filings since AY 2023-24.

A new chapter and new numbering. Section 348 is the audit provision under the 2025 Act; the old section references in a trust's permanent file will not resolve.

Two things not yet settled. Sources differ on the governing rule — most cite rule 186 of the Income-tax Rules, 2026, some cite rule 188, and at least one describes the rules it is citing as draft. Until that is confirmed from the notified text, a working paper that cites a rule number is citing a coin toss.

What to do

  • File this year on 10B or 10BB. Nothing about that has changed.
  • Check the three tests against the provision, not against a summary, before settling on 10BB for a client who receives foreign contributions or spends abroad.
  • Get the report in before the return. 21 October, then 21 November.
  • Leave Form 112 for the planning file. Note it, note that the rule number is unconfirmed, and look at it again when the first tax-year-2026-27 audits come round — by which time the notified text will have settled what commentary currently has not.

Questions this answers

Does a trust file Form 112 or Form 10B this year?

For the year ended 31 March 2026 it is Form 10B or Form 10BB, because that income is assessed under the Income-tax Act, 1961. Form 112 is the audit report under section 348 of the Income-tax Act, 2025 and applies from tax year 2026-27 onwards.

What is Form 112?

The unified audit report for registered non-profit organisations under section 348 of the Income-tax Act, 2025. It replaces Forms 10B and 10BB with a single form, removing the annual judgement about which of the two applies.

When is the trust audit report due for AY 2026-27?

21 October 2026, extended by CBDT Circular 07/2026 from 30 September. For covered cases the return moves to 21 November 2026, and the audit report has to be in place before the return is filed.

How do I choose between Form 10B and Form 10BB?

Form 10B is indicated where total income exceeds ₹5 crore before giving effect to the exemptions, where any foreign contribution has been received, or where income has been applied outside India; otherwise Form 10BB. Sources describe those tests inconsistently, so check the provision — choosing the lighter form wrongly produces a defective report.

Which rule governs Form 112?

That is not settled in the commentary. Most sources cite rule 186 of the Income-tax Rules, 2026, some cite rule 188, and at least one describes the rules it cites as draft. It is worth confirming against the notified text before a working paper cites a number.

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