Compliance Review & Regularisation

• Income Tax: Check ITR-7 filing history for last 6 years, identify unfiled years, Form 10B filing status, TAN registration and TDS return status, 12A/80G certificate validity
• MCA (Section 8 companies): Check MCA master data, AOC-4 and MGT-7A filing status, DIN/DSC validity, DIR-3 KYC status, outstanding penalties on MCA21
• FCRA: Verify FCRA registration validity and expiry date, FC-4 filing history, SBI FCRA account compliance, sub-grant compliance
• Registrar of Societies: Annual return filing status, managing committee data currency
• NGO Darpan: Profile activity status, last update date, completeness of information
• Statutory Audit: Whether annual audits have been conducted and Form 10B filed for each year

• ITR-7 not filed for one or more years — often goes unnoticed until 12A renewal is rejected
• Form 10B not filed separately (auditor submitted accounts but not the formal Form 10B on IT portal)
• 12A/80G certificate lapsed — particularly common for NGOs with pre-2021 registrations that missed revalidation deadline
• Section 8 company: DIR-3 KYC not filed → DINs of directors deactivated → all MCA filings blocked
• FC-4 filed late or missing for one year — FCRA renewal application will flag this
• Darpan profile not updated for 2–3 years — marked inactive
• Form 10BD (donor statement) not filed — donors unable to claim 80G deductions
• TDS not deducted on staff salaries or contractor payments

1. Compliance Audit Report: Complete gap analysis delivered within 5 working days of document collection
2. Prioritisation: Critical gaps (lapsed 12A, deactivated DINs, missing FC-4) addressed first
3. Belated Returns: File ITR-7, AOC-4, MGT-7A, FC-4 for missed years with applicable penalties
4. Certificate Renewal: File Form 10AB for lapsed 12A/80G; FC-3C for lapsed FCRA; DIR-3 KYC for deactivated DINs
5. Portal Updates: Reactivate Darpan profile; update MCA master data; file FC-6 for changed details on FCRA portal
6. Notice Management: Respond to any outstanding notices from Income Tax, MCA, or MHA
7. Clean Compliance Platform: Establish forward-looking compliance calendar to prevent future gaps

Q: Can old ITR-7 returns be filed retrospectively?
Updated ITR (formerly belated return) can be filed for the immediately preceding assessment year. For older years, a condonation of delay application to the Commissioner of Income Tax is required. MFiling handles both — filing updates for recent years and preparing condonation applications for older missed years. MHA also accepts FC-4 for missed years with applicable explanation.

Q: Will regularisation protect the NGO from penalties for past violations?
Voluntary regularisation significantly reduces penalty risk compared to reactive compliance after a government notice or raid. Courts and tribunals consistently give credit for proactive regularisation efforts. MFiling documents the regularisation process comprehensively so that if any authority raises a question about past compliance gaps, we can demonstrate good-faith remediation.