Charity Commissioner Submission –
Annual Accounts, Change Reports & Bombay Public Trusts Act Compliance
Every registered charitable trust in Maharashtra must file annual accounts, change reports, and property returns with the Charity Commissioner under the Bombay Public Trusts Act, 1950 — separately from, and in addition to, income tax compliance under ITR-7.
Overview
What Is Charity Commissioner Submission?
Charity Commissioner submission covers all statutory filings under the Bombay Public Trusts Act, 1950. The Charity Commissioner supervises all public trusts in Maharashtra — monitoring fund application, trust governance, and property use. Every registered charitable trust, educational trust, religious trust, healthcare trust, and welfare organisation, as well as societies deemed public trusts under the Act, must comply.
N D Savla & Associates provides complete Charity Commissioner filing Maharashtra services — public trust annual accounts, change reports, property approvals, and officer notices. Our service connects with our Trust Audit Services, ITR-7 Return Filing, 12A and 80G Registration, and Form 10BD Filing — so the full annual cycle runs together.
Two Separate Compliance Tracks — Both Mandatory Every Year
Charity Commissioner Track
Income Tax Track
Primary Annual Filing
Annual Accounts Submission to the Charity Commissioner
The public trust annual accounts submission is the most important Charity Commissioner filing each year. The trust must submit audited accounts by 30 September — covering the financial year ending 31 March. Our Trust Audit Services coordinate the audit and the Charity Commissioner filing Maharashtra together from the same set of financial records.
What the Submission Must Include
Audited Income & Expenditure Account
CA-certified I&E account for the year. Must demonstrate charitable application of funds consistent with registered objects.
Balance Sheet
Showing all assets and liabilities of the trust as at 31 March. Properties, investments, and corpus funds disclosed separately.
Receipts & Payments Account
Detailed cash and bank movement summary for the year — all inflows and outflows with bank reconciliation.
Activity Report
Summary of charitable work undertaken during the year — programmes run, beneficiaries reached, and funds utilised per activity.
Late public trust annual accounts submission attracts penalties under the Bombay Public Trusts Act. The Charity Commissioner can issue a show cause notice to trustees personally. Repeated non-filing may trigger a formal inquiry — including potential trustee removal and court-supervised administration. Additionally, a history of late filing damages the trust's credibility with CSR donors and government grant programmes.
Ongoing Obligation
Change Report Filing with the Charity Commissioner
A change report Charity Commissioner filing is required within 90 days whenever registered details change. This is entirely separate from the annual accounts submission and runs throughout the year. Missing the 90-day window makes the Charity Commissioner's records inconsistent with the trust's actual situation — creating legal problems for property transactions and grant applications.
Events That Require a Change Report
Trustee Change
New appointments, resignations, or deaths of trustees
Registered Address Change
Change in the trust's principal registered office address
Trust Deed Amendment
Any change to the objects, powers, or governance provisions
Property Acquisition or Disposal
Addition or removal of any immovable property from the trust
Bank Account Change
New bank account, changed account number, or changed bank
Trustee PAN or Address Update
Change in any trustee's PAN details or personal address
A trustee not recorded in the Charity Commissioner register cannot legally represent the trust. Without a current change report, government grant applications and no-objection certificates fail. Property transactions where the trust's registered details do not match the Charity Commissioner records are legally voidable. We file change reports proactively — within the 90-day window — for all registered charitable trust India clients.
Often Overlooked
Trust Property Submissions and Prior Permission
Charitable trust Maharashtra compliance also covers property submissions — frequently overlooked but legally mandatory under the Bombay Public Trusts Act. Getting this wrong can void the transaction entirely.
Trusts holding immovable property must also file annual property returns alongside the public trust annual accounts — detailing all properties, their current value, and income generated. This return is the documentary foundation for any future property proceedings and must reach the Charity Commissioner before the 30 September deadline alongside the annual accounts.
When Things Go Wrong
Responding to Charity Commissioner Notices
Compliance failures trigger show cause notices from the Charity Commissioner — formal legal documents that the trust or trustees must respond to in writing within the specified period. The way these are handled determines whether the matter ends at the notice stage or escalates to formal inquiry.
The trust receives a show cause notice specifying the compliance failure — typically missed annual accounts, outdated change report, or an unreported property transaction. The response deadline is usually 15 to 30 days.
An ex-parte adverse order issues automatically. This is far harder to challenge than a timely response. Outcomes can include formal trustee censure, financial penalties, or referral to a Section 41 inquiry.
The response is factual, document-supported, and filed within the deadline. Where the notice arose from a missed Charity Commissioner submission, we file the catch-up accounts alongside the response — demonstrating the default has been remedied. This typically avoids all further enforcement proceedings.
In serious cases, the Charity Commissioner initiates a formal inquiry under Section 41 of the Bombay Public Trusts Act — with notices, hearings, and a final order. Possible outcomes include trustee removal or appointment of a court-supervised administrator. However, formal inquiries are almost always avoidable when annual Charity Commissioner filing Maharashtra stays current.
The Full Picture
Complete Annual Compliance Calendar — Charity Commissioner + Income Tax
A registered charitable trust in Maharashtra runs two parallel compliance tracks each year. Managing both together prevents deadline conflicts. The Charity Commissioner deadline of 30 September comes before the income tax deadline of 31 October — so Charity Commissioner preparation must begin in June, not August.
Account Finalisation and Audit Commencement
The trust finalises accounts for the year ending 31 March. The auditor reviews income, expenditure, and bank reconciliations. Both the Charity Commissioner accounts and the Form 10B audit for income tax use the same financial records — coordinating both in April saves time and avoids duplication.
Form 10BD Filing Deadline
Trusts with 80G registration must file the annual donor statement Form 10BD by 31 May. Our Form 10BD Filing service manages this deadline — and generates Form 10BE donor certificates that enable donors to claim Section 80G deductions.
Dual Submission Window — Charity Commissioner + Form 10B
Two filings run simultaneously during this period. First, the Form 10B audit is completed and uploaded to the income tax portal. Second, the Charity Commissioner submission is prepared and filed. Both use the same audited accounts. We coordinate both to ensure the 30 September Charity Commissioner deadline is met before the October income tax window opens.
Charity Commissioner Annual Accounts Deadline
Public trust annual accounts — I&E account, balance sheet, receipts & payments, activity report, and property return — must submit to the Charity Commissioner via MahaOnline by 30 September. This is the primary Charity Commissioner submission deadline of the year.
ITR-7 Filing Deadline
By 31 October, the trust must file ITR-7 with the income tax department. The Form 10B acknowledgement number must appear in the ITR-7. Therefore, the Form 10B audit must complete before ITR-7 filing begins.
Section 12AB & 80G Renewal + Change Reports
Throughout the year, the trust must monitor its Section 12AB and 80G registration renewal deadlines — both are valid for 5 years and must renew at least 6 months before expiry. Additionally, any change in trustees, address, deed, or property triggers a Charity Commissioner change report within 90 days of the event.
Our Services
Our Charity Commissioner Submission Services at N D Savla & Associates
We provide end-to-end Charity Commissioner filing Maharashtra — from public trust annual accounts preparation through MahaOnline submission, change reports, property permission applications, and show cause notice responses.
