Harsh
ABSTRACT
India is a nation with enormous philanthropic potential, and it is home to millions of registered NGOs. The present study is a report on the regulatory framework for Voluntary Organizations in the country. It is hypothesized that the primary factors plaguing the voluntary sector in India are (a) excessive governmental oversight and bureaucratic requirements, and (b) ineffective tax compliance and incentive structure. The analytical input for the study has been derived from the relevant studies conducted by the Centre for Budget and Governance Accountability (CBGA), the Centre for Social Impact and Philanthropy (CSIP), and other credible research centers. In addition to the private sector studies, policy statements and government reports have also been referred to constantly. The study is further enriched by a comparative analysis of relevant laws across countries. The recommendations made have been drafted keeping in mind the aspirations of the government as expressed in the National Policy on Voluntary Sector (2007).
Keywords: NGO, Voluntary Organization, Charity, Poverty, Tax Incentive, Regulation, Bureaucracy
1. REVIEW OF LITERATURE
The Voluntary Action Cell (2007) constituted by the (Planning Commission) published the “National Policy on the Voluntary Sector” in May 2007. The report starts with defining what comprises a voluntary organization. The characterization includes autonomy, well defined objectives, and non-distribution of profit to the directors. Moving on, the policy discusses certain problems that the Indian voluntary sector is faced with and proposes possible remedial measures. The first objective of the policy is to create “an enabling environment” for VOs. TO achieve this, several recommendations have been made pertaining to the simplification of procedures around registration and compliance. The document also stresses the need to establish a rational tax incentive system. Recognizing the role of foreign funding in the operation of VOs, the policy once again proposes liberalisation of the respective rules. Next, the policy moves on to discuss the ways to develop better cooperation between the government and the VOs, but this lies outside of the scope of the current article.
Centre for Social Impact and Philanthropy (2021) has commissioned a study titled “Tax Incentives for Philanthropic Giving: A Study of Twelve Countries (2021).” The said report is a comparative study of the tax incentives offered in twelve different countries. A comprehensive analysis of data from 12 countries shows that India lies somewhere in the middle when it comes to the generosity of its tax incentives. The study mentioned above draws this conclusion by analyzing the data on all four factors mentioned above[1]. The following table serves as an illustration of this point. The report further declares the UK, France and Singapore as nations with the most generous tax incentive system. On the other hand, South Africa, Brazil and Mexico appear to lie on the other end of the spectrum (having the least generous incentive system). Many more observations made in the said report are mentioned in this research paper. The article concludes with several reform recommendations aimed toward creating a more incentivizing environment for donors and philanthropists.
Centre for Social Impact and Philanthropy (2020) published a study entitled “Regulatory Frameworks for India’s Voluntary Sector: Global and Cross-sectoral Review of Initiatives and Practices.” The research paper explores the existing regulatory frameworks and practices concerning Voluntary Organizations. The study strives to arrive at methods to boost public confidence, reduce regulatory burdens, and ensure that India's voluntary sector has autonomy and high levels of professionalism. The report also focusses on the tax regime, and offers a fair critique of the same. Some of its recommendations include- Introducing enabling and supportive policies and legal reform in consultation with VO stakeholders; Increasing the participation of umbrella organizations/intermediaries, significant donors, and VOs in sector-led initiatives; Endorsing projects by recognizing developed codes and standards and appointing accreditation institutions to certify complying VOs. The study has been referred to multiple times in the current article.
The Steering Commission (2002) published the “Report on Voluntary Sector” in the January of 2002. The document extensively highlights the significance of Voluntary Organizations at the national and the international level. For instance, it discusses the role played by VOs since ancient times. Hindus had Maths and Ashrams, Muslims had Waqfs and Khanqahs, while Sikhs had Gurudwaras and Deras. These institutions used to offer fooding, housing, and spiritual services to the needy. In the olden days, the king was seen as the guardian of his people. However, some people inevitably ended up impoverished and disenfranchised. Philanthropic institutions of the past used to help such ill-fated people. The report then discusses the way to promote government-VO partnership and methods of capacity-building for VOs. The last segment, therefore, lies outside of the scope of this article.
2. THE EXISTING REGULATORY FRAMEWORK: THE FLAWS
2.1. An Introduction to Voluntary Organizations
The National Policy on Voluntary Sector (2007)[2] defines Voluntary Organizations (VOs) as “organizations engaged in public service”. Such organizations usually function around cultural, social, economic, ethical, religious, spiritual, philanthropic or scientific considerations. The policy further annexes some conditions to this definition. It mandates that VOs should be private organizations, and they should not return profits (generated) to their owners or directors. All associations [NGOs, Trusts, Charities, etc.] that fulfill the above conditions fall within the category of VOs. HelpAge India and CRY are two popular examples.
The 10th Five Year Plan is the most concrete expression of the government’s vision on the role of VOs in Indian society. The policy statement, by all means, is a progressive one. It acknowledges the importance of VOs in building a thriving participatory democracy. Despite the recognition VOs have attained on paper, the philanthropic capital of India has remained underutilized. This paper looks at some of the issues plaguing the Voluntary Sector and suggests possible ameliorative measures. The fine print of the policy report reveals the target of creating an “enabling environment" for VOs and supporting their efficiency and autonomy. Other objectives of the said policy include: enabling VOs to mobilize financial resources (domestically and from abroad); improving transparency and management among VOs, and promoting public-VO partnerships.[3] We can understand the persistent problems around VOs by zeroing down on the abovementioned objectives individually. The first step toward creating an "enabling environment" would be to get the Voluntary Organization registered. The following section runs through what exactly this entails.
2.2. Registration & Incorporation: The Core Issues
The story of a Voluntary Organization begins with its registration. These Organizations may get themselves registered as "societies, as charitable trusts, or as non-profit companies[4]" under Central or State laws. NGOs/Charities/Trusts fall in the concurrent list, and both the union and the states have the power to make laws for the registration and incorporation of VOs. Registration laws can also vary widely between two states. While some states have imported the Societies Registration Act (1860) into their law, others have either made extensive amendments or have enacted new laws altogether. Consequently, we have a multitude of acts like the Andhra Pradesh (Charitable and Religious Institutions and Endowments Act 1966) and the Tamil Nadu (Hindu Religious and Charitable Endowments Act, 1959). The state of Tamil Nadu has another legislation for Islamic trusts (Waqf Act, 1995).[5]
The required compliance depends upon the applicable law, which in turn depends on the place of origin, and nature of the entity seeking registration. For instance, a charitable trust set up in Delhi would be subject to fewer compliance requirements, while one registered in Mumbai would have to submit annual returns, and seek prior approval from the Charities Commissioner, etc. Additionally, some states also require regular renewal of licenses. Not surprisingly, this only adds to the compliance burden of Voluntary Organizations (like Jammu and Kashmir, Uttar Pradesh, Assam etc.).[6] The table below summarizes the national laws that apply to different types of Voluntary Organizations[7]
Type of Voluntary Organization | Registered Society | Trust | Nonprofit Companies |
Applicable (National) Law | Registration of Societies Act, 1860 | State Laws Apply along with the principles of the Indian Trusts Act, 1882 | Indian Companies Act, 2013 |
Timeline of Formation | 30-45 days | 10-15 days | 60-75 days |
Compliance Requirements | Relatively less regulation, basic provisions governing acquisition/disposal of property, alteration and dissolution. | Trusts have to register with the regional Charities Commissioner (CC). Alterations and changes have to be disclosed, and accounts are to be audited under CCs supervision. | Companies are required to conduct board and general meetings, file annual accounts with the Ministry of Corporate Affairs, maintain requisite registers, etc. |
These differences appear confusing at best and restrictive at worse. The National Voluntary Sector Policy (2007) takes cognizance of the issue. It mentions how-
“Over time, many of these laws and their corresponding rules have become complex and restrictive, thus leading to delays, harassment and corruption.”[8]
The same document also proposes some interesting solutions to the said problem. It says that the government will strive to simplify, liberalise, and rationalise the rules for registration. However, what stands out is the idea of a uniform VO registration law. The policy states that the government will consider the feasibility of bringing in a pan-India liberal statute for registering VOs. The said statute would not replace existing laws but will be providing VOs seeking registration with an alternate route. Therefore, the law would co-exist with the existing legislations.
The problems with registration rules do not end with convoluted procedures. The lack of tailored policy for specific types of VOs is also an issue. For example, there is no exclusive legislation for VOs engaged in developmental or charitable work. In practice, this means that developmental VOs like a "resident’s welfare association" will be faced with the same compliance requirement as a recreational activity centered VO. Additionally, even when a VO manages to get through the cumbersome and confusing registration process, inter-state operations still pose a challenge. This is not surprising as different states have different rules and regulations (as discussed previously).[9]
In conclusion, despite the policy’s aims to establish a simple operational framework, much still remains to be done. A fragmented legal regime, unnecessary impediments to registration and problems with interstate operations are some of the major complications that need to be remedied.[10]
2.3. Problems with the Tax Policy
The tax policy around VOs can be studied under two heads. The first category would be the (a)tax compliance requirements that VOs are mandated to follow while operating. Next, we can look at the (b) tax incentives that individuals and corporations get entitled to when they make a financial contribution to a Voluntary Organization. I will first present a rundown of the compliance requirements. After having summarised the basics of the taxation structure, it would be appropriate to discuss certain faultlines.
3. TAX STRUCTURE AND RULES FOR VOLUNTARY ORGANISATIONS
Contrary to popular belief, NGOs and Charitable Organizations are not entirely exempt from paying taxes. In fact, all NGOs/Trusts are required to file income tax under section 12 of the Income Tax Act. It is after fulfilling certain conditions that VOs become eligible for tax exemptions. Firstly, the VO must be registered under section 12AA of the said Act. Another requirement is that the organization should apply a minimum of 85% of its total income to philanthropic endeavours falling in one of the falling categories[11]:
Relief to the financially impoverished, Yoga, Medical Relief, Education, Environmental Preservation (including the preservation of monuments and places or objects of artistic or historical interest), and for the furtherance of any other object of general public utility[12].
Lastly, if an NGO or a trust (working for the advancement of an “object of general public utility”) engages in commercial activities (for a fee), the income from such activity should not exceed 20% of the net receipts. If a VO manages to comply with all of the above requirements, it becomes eligible to file income tax returns (thereby enjoying the benefits of exemption).
The Income Tax ACT (1961) is not the only relevant legislation in relation to the income of VOs. The FCRA (Foreign Contributions Regulation Act) and the GST (Goods and Services Tax) Act of 2017 also contain certain compliance requirements. A Voluntary Organization may be required to file income tax if its income exceeds the threshold of 2 million Rupees annually. However, the GST act contains exemption provisions for a small group of VOs (The definition of the term "Charitable Act" is narrower under the GST ACT when compared to the Income Tax Act). The fact that the GST applies to VOs goes against the Act's key objective. The GST Act was legislated to tax entities that operate in furtherance of business, which is not the primary function of VOs[13]. As a matter of fact, VOs are not allowed to distribute profits to their directors.
The FCRA provides the rules and procedures for receiving and applying foreign contributions. A VO needs to be registered with the Ministry of Home Affairs to be eligible for foreign funding. A registration lasts for five years before expiring. Alternatively, the VO can directly apply for permission to receive a one-time sum. Further, the VO must publicly disclose this income by filing quarterly receipts. Its primary objective is to prevent the application of foreign money to endeavors detrimental to the national interest. While it is fundamental to check activities that run contrary to the public interest, the law, and at the very least, its implementation, is widely seen as draconian and restrictive. Allegations around the use of FCRA as a political tool often break headlines[14].
As of now, all the VOs in India are subject to the same tax compliance requirements. What this means is that the law is blind to the size or ability of VOs. A small NGO made up of a dozen volunteers will have to comply with the same regulations as an NGO with offices panning all across India. This poses a problem for VOs operating at a small scale as the smaller organizations lack the resources to conform to complex compliance requirements. To lower their burden of compliance, the policy should be nuanced enough to have room for differential treatment. Furthermore, the differences are not limited to the size of VOs. Factors like the nature of work and sources of funding should also be kept in mind while drafting policy.
Another policy flaw that impedes the healthy participation of VOs in our democracy is non-uniformity (of provisions and definitions). For instance, different laws define "charitable purpose" differently. On a comparative note, the Income Tax Act presents a broader definition, while the GST Act contains a narrower one. The former includes areas of poverty relief, environmental conservation, conservation of objects or places of historical or artistic importance, and "advancement of general public utility". However, the GST act limits the meaning of "charitable work" to the field of education, public health, environment, and religious activity.[15]
Additionally, different government bodies may interpret the same Act inconsistently. For instance, what counts as an "object of general public utility" is clearly a question of fact. As a result, the manner of interpretation becomes subject to executive discretion. Differences between state laws do not help in remedying the existing complexities. The following example illustrates this point:
While the Income Tax Act, 1961 (Central) allows VOs to invest in mutual funds, VOs registered under the FCRA act are not allowed to do the same. In contrast, Voluntary Organizations registered under the Maharashtra Public (Trusts) Act can only invest in specified debt-based mutual fund units. [16]
Having briefly covered the tax structure, we can now look at the tax benefits citizens and corporations receive when they donate to VOs in India.
4. TAX INCENTIVES FOR DONATIONS
Policymakers often use tax incentives to promote a particular kind of economic activity. For instance, if a government wants to incentivize the buying of houses, it can do so by offering tax benefits. The US tax code, for example, does not include the money spent on mortgage payments in the category of taxable income. Therefore, mortgage payments become "tax-deductible". Similarly, many legal systems use tax incentives to promote donations to organizations undertaking charitable work. In the absence of such a policy, the cost of a philanthropic contribution would be equal to any other commercial expenditure. Therefore, tax benefits reduce the effective cost of philanthropy. A study by the Centre for Budget and Governance Accountability (CBGA) found that “simple and accessible tax incentives generally have a positive influence on the level of giving.”[17]
Of course, charitable giving also depends upon factors like the culture of giving, personal traits, economic development, etc.[18]
The impact of tax benefits may vary depending upon (a) The Form of Incentive; (b) Existing Tax Rates; (c) the Rate of Incentive; (d) the Incentive Ceiling. The following table serves as an illustration to this point.
Form of Incentive | Tax Deductible Income | Tax Credit |
Definition | Certain forms of expenditure are eligible to be treated as tax deductibles. In practice, it means that the money spent is not treated as “taxable income”. | Tax Credits directly reduce the tax liability of the assessee. It is different from tax deductions that do not directly reduce the tax bill, but cut down the “taxable income.” |
Impact of Tax Rates | If the rate of tax is higher, provisions for tax deductions would make donations to charities more lucrative | The impact of tax Credits, on the other hand, is not affected by the prevailing tax rate. |
In addition to these factors, the non-monetary aspects of the incentive system are equally important. For instance, what causes are eligible for benefits or the fairness and efficiency of the system are crucial in determining the effect of tax benefits. The broader point is that several variables are involved here, and each one impacts the generosity of donations differently.[19] We will now look at some problems associated with this system.
In 2021, the Centre for Social Impact and Philanthropy (CSIP)[20] commissioned a study to find out ways to encourage charitable donations in India. The project culminated in a comparative study of 12 countries concerning their tax incentive systems for VOs. The following few paragraphs would make constant reference to the study.
A comprehensive analysis of data from 12 countries shows that India lies somewhere in the middle when it comes to the generosity of its tax incentives. The study mentioned above draws this conclusion by analyzing the data on all four factors mentioned above[21]. The following table serves as an illustration to this point. The report further declares the UK, France and Singapore as nations with the most generous tax incentive system. On the other hand, South Africa, Brazil and Mexico appear to lie on the other end of the spectrum (having the least generous incentive system). The table below compares the incentives that countries provide on various categories of taxes:
India, like most other countries, provides tax incentives on personal income tax and corporate tax. However, the CSIP commissioned study found that 6 out of the 12 countries also offer incentives on Inheritance tax. The same is not the case in India, as the country does not levy inheritance taxes. It may be argued that the "absence of an inheritance tax in India lowers the motivation to donate"[23]. Similarly, India also scraped its wealth tax in 2017[24]. What follows is that a wealth tax incentive is also not an option in India.
Furthermore, 9 of the 12 countries surveyed allow tax benefits for cross-border donations. In India, however, donations to VOs based outside of India do not qualify for tax exemptions. Other countries that stand out in this regard are China and Singapore.[25]
The study reveals a unique problem that VOs in India might be enduring, i.e., competition from government funds and entities. Out of the 12 countries surveyed, India came out as the only country that offers tax exemptions on donations made to public bodies and funds. The most popular Indian tax incentive scheme is found in section 80G (of the Indian Tax Code), which allows for a 50% deduction on taxable income (of the amount spent on charity/donation). However, the same section provides for a 100% deduction in taxable income for contributions made to certain government entities/funds.
The saga of this unhealthy competition does not end at unfair incentive rates. The ceiling rate is also a problem sui generis. Contributions to VOs are eligible for tax exemptions only so long as they do not exceed the ceiling of 10% of the taxable income. Any donation over the 10% threshold is ineligible to avail of the benefits of the 80G scheme. The data from the comparative study reveals that out of the 12 countries, 8 have a ceiling rate of 100% or more. The table below illustrates this point:
While these provisions appear restrictive in their own right, it gets worse. The ceiling rate for donations to public funds and entities is a solid 100%. In this light, Indian philanthropists would have a higher financial incentive to donate to government funds (instead of supplying resources to VOs).
Section 80G of the Indian Tax Code has not gone through any major liberalizing amendment in the past four decades. The law has only witnessed the addition of a few government entities and funds to the list (of entities eligible for exemption). In fact, the generosity of the tax incentive structure has gone down with time. For example, in 2020, an optional tax regime was introduced. The taxpayers can now choose between two alternative tax structures. While the newer system offers low tax rates, the tax benefits on donations are less generous. The case with the older system is quite the opposite. It does offer a more liberal incentive system, but the tax rates are relatively higher.[27] This puts the donors into an unnecessary conundrum. Moreover, the recent years have witnessed a reduction in the rates of personal income tax and corporate tax. As a result, the (static) tax incentives have become less attractive. All of this translates to an increased effective cost of philanthropy.
The lack of will (among policymakers) to liberalize the incentive structure can also be gauged by looking at the pandemic situation. The following is a direct quotation from the policy brief[28] of the CSIP study:
“In the sample of 12 countries, while the USA and China increased the level of benefit, India did not do any such thing. In India, the only change was the introduction of a new fund called PM CARES[29].”
5. THE WAY FORWARD
As mentioned earlier, Voluntary Organizations are crucial to the functioning of a participatory democracy. The importance of this sector was also touched upon in the introductory section. Subsequently, I discussed various faultlines in the current legislative framework. It is only logical to consider possible remedial steps at this stage. The 2007 policy[30] mentions some progressive and noble objectives. Therefore, it should serve as a decent roadmap while planning forward. The following paragraphs will offer some recommendations keeping in mind the goals set by the said policy.
Independence is emblematic of the very idea of a voluntary organization. Therefore, the first step should be to ensure that VOs can undertake autonomous operations without crumbling under the burden of regulatory overreach. A singular statutory amendment will not go far in achieving this goal. A slew of measures would have to be taken. In the end, all statutes, rules, and regulations should be such that the autonomy of VOs remains uncompromised. At the same time, VOs must also be held accountable if they undertake activities detrimental to the public interest.[31] A dilemma arises when trying to balance the need for transparency and autonomy. A viable solution would be the evolution of "an independent, national level, self-regulatory agency for the voluntary sector"[32]. This would ensure accountable governance and management without affecting the independence of VOs. Another way to achieve accountability without having tightrope restrictions is by opening up VOs to public scrutiny. For example, the National voluntary sector policy recommends the introduction of norms for filing basic documents (e.g., related to income tax). These documents could then be made available in the public domain. The filed information can also be available on a government website. This would go a long way in promoting the spirit of public oversight.
The convoluted registration process is an issue that requires immediate redressal. For instance, the procedures under section 25 of the Companies Act (which contains provisions for the registration, license and remuneration) are unnecessarily cumbersome. There is a need to rationalise and simplify the registration laws. As mentioned earlier, the policy makes an interesting suggestion regarding this, i.e., the introduction of pan-India optional registration law. The feasibility of such a measure should be explored by commissioning relevant research and studies. Additionally, to achieve said simplification, the following areas can be focused on:
(a) development of an online registration process (can be achieved by the use of an online data base that keeps track of all registration activity), (b) establishing a universal definition for the "charitable purpose", (c) A common classification system (typology) for Voluntary Organization[33]
In our discussion on the compliance rules, the issue of the need to regularly renew licenses was also taken up. The same can be addressed by making the license non-lapsable, given that the VOs consistently file their respective Income Tax/ GST returns. This has been recommended by a CSIP commissioned study (on the Legal, Regulatory, and Grants-in-Aid Systems for India’s Voluntary Sector).[34]
Having discussed some recommendations for the regulatory framework, we can move to suggestions for the tax regime. First of all, there is a need to conduct a thorough study on the efficiency and usefulness of the current Income Tax regime. Such a study should cover two aspects, i.e., the tax compliance requirements, and the tax incentive structure. Otherwise, eliminating harmful laws and bringing in better ones won't be possible.
As discussed earlier, a major problem is the multiplicity of compliance requirements (under various statutes like the Income Tax Code, the GST Act, and the FCRA). In this light, it would be immensely helpful to ensure better cooperation between different departments and bodies (e.g., the FCRA, Income tax authorities, and the Registrar of Societies). There is also a need to bring more nuance to the tax law. The compliance requirements for VOs operating in different capacities should be stratified. For instance, differential treatment of VOs that create some social impact vis a vis recreational/ non-social impact VOs could be fruitful. Regard should also be had to the scale of operation of a VO. An NGO operating at a small scale cannot be expected to comply with the rules meant for large-scale VOs.
An amendment to section 2(15) of the Income Tax Act, 1961 should also be considered. As discussed previously, this section places a limit of 20% on the share of receipts from commercial services (for VOs working to further an “object of general public utility"). The revision should ensure that VOs working under all categories get to engage in commercial activities without any financial limit.
Next, we can move to recommendations around the tax incentive policy. Once again, the first step towards progress should be the commissioning of rigorous studies on the subject. This will help the legislators undertake evidence-based policymaking. As discussed previously, multiple variables impact the quantum of philanthropy. Merely increasing the rate of incentive might not be helpful, if other factors (like economic development, incentive ceiling, corruption, etc.) are not favourable. It would not be prudent to initiate sweeping reforms in absence of quality empirical evidence. Political ideology should not take over the role of academic research.
Nevertheless, few tweaks appear reasonable, at least after a surface-level investigation. First such change might be to offer tax exemptions to Indian philanthropists on donations they make to VOs based outside of India. Secondly, wealth tax and inheritance tax could be introduced. These taxes tend to affect the higher income groups and are therefore progressive. In addition to the creation of a new source of revenue for the government, such a measure would also allow for a new form of donation incentive. The government would be able to offer exemptions on these categories of taxes. Further, these incentives would cater to the strata of the society with higher financial capacity (making them more likely to donate). Lastly, the possibility of raising the rate of incentive and ceiling should be looked into. To reiterate, any policy change should be backed by thorough research and data.[35]
[1] i.e. (a) The Form of Incentive; (b) Existing Tax Rates; (c) the Rate of Incentive; and (d) the Incentive Ceiling.
[2] Voluntary Action Cell (Planning Commission), National Policy on Voluntary Sector 1 (2007)
[3] National Policy on Voluntary Sector, supra note 1, at 2
[4] Under Section 8 of the Companies Act, 2013
[5] Centre for Social Impact and Philanthropy, A Study on the Legal, Regulatory, and Grants-in-Aid Systems for India’s Voluntary Sector 18 (2020)
[6] Centre for Social Impact and Philanthropy, supra note 6, at 23
[7] Id. at 19
[8] National Policy on Voluntary Sector, supra note 1, at 3
[9] Centre for Social Impact and Philanthropy, supra note 5, at 21
[10] Id. at 21
[11] Income Tax Department, https://www.incometaxindia.gov.in/pages/acts/income-tax-act.aspx (last visited May 11, 2022)
[12] ClearTax, https://cleartax.in/s/charitable-trusts-ngo-income-tax-benefits)
[13] Centre for Social Impact and Philanthropy, supra note 5, at 22
[14] FRONTLINE, https://frontline.thehindu.com/cover-story/weaponising-fcra-controversy-surrounds-govt-refusal-to-renew-licence-of-missionaries-of-charity/article38192422.ece#:~:text=Missionaries%20of%20Charity-,Weaponising%20FCRA%3A%20Controversy%20surrounds%20govt%20refusal%20to,licence%20of%20Missionaries%20of%20Charity&text=The%20controversy%20over%20the%20FCRA,especially%20those%20run%20by%20Christians. (last visited May 12, 2022)
[15] Centre for Social Impact and Philanthropy, supra note 5, at 21
[16] Id. at 21
[17] CSIP, https://csip.ashoka.edu.in/research-and-knowledge/#report (last visited May 12, 2022)
[18] Centre for Social Impact and Philanthropy, How India can Encourage Charitable Donations: A Policy Brief 2 (2021)
[19] Id. at 2
[20] Centre for Social Impact and Philanthropy, Report on Tax Incentives for Philanthropic Giving: A Study of 12 Countries 1 (2021), (The Centre for Social Impact and Philanthropy is a Research Centre which operates under the aegis of the Ashoka University.)
[21] i.e. (a) The Form of Incentive; (b) Existing Tax Rates; (c) the Rate of Incentive; and (d) the Incentive Ceiling.
[22] Centre for Social Impact and Philanthropy, supra note 16, at 3
[23] Id. at 3
[24] The Economic Times, https://economictimes.indiatimes.com/news/economy/policy/can-india-go-back-to-a-wealth-tax-by-appealing-to-the-better-side-of-the-rich/articleshow/89056174.cms (last visited May 12, 2022)
[25] Centre for Social Impact and Philanthropy, supra note 16, at 4
[26] Id. at 4
[27] Forbes, https://www.forbes.com/advisor/in/tax/old-vs-new-tax-regime-which-one-should-you-choose/ (last visited May 12, 2022)
[28] Centre for Social Impact and Philanthropy, supra note 16, at 5
[29] PM CARE stands for Prime Minister’s Citizen Assistance and Relief in Emergency Situations
[30] National Policy on Voluntary Sector, supra note 1
[31] Id. at 2
[32] Id. at 4
[33] Centre for Social Impact and Philanthropy, supra note 6, at 23
[34] Id. at 23
[35]Centre for Social Impact and Philanthropy, How India can Encourage Charitable Donations: A Policy Brief 7 (2021)
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