Dear Sir,
How to deal a situation when you have a Prior permission FCRA account and also the organisation received a permanent registration.
Do we need to file two separate Annual return or it can be mergered into one return.
As the organisation has two fcra bank account one for prior permission and another for permanent registration.
Kindly clarify.
Thanking you,
With warm regards,
Ravistan Anthony
What Shiva says is correct that one should have only one FCRA Bank account for receipt of funds, generally one can give the same account no, while applying for FCRA Registration. Thus problem of having two bank accounts would not arise in the first place. At this stage, since you have received funds in two accounts and there are balances in two different accounts at the end of the year, you could even file two returns, one for Prior permission and other for Registration. But do try to close your prior permission account at the earliest. Treating prior permission account as Utilisation Account would not be proper, since you are required to intimate within 15 days of opening of any Utilisation account.
When you got prior permission, you started receiving the permitted foreign fund in a bank account. When that account is there, I don’t understand why you had opened another account for getting permanent registration, because you should have mentioned the fact of your having prior permission and the bank account number, while applying for permanent registration. Any way, if you are transacting foreign funds through two accounts, you have to first intimate the home ministry about that while filing annual return. The FCRA Act/Rule says that you should have only one bank account to receive foreign fund for your organisation and you may have more than one account for utilisation purpose. You may retain the bank account number mentioned in your permanent FCRA order and merge the one you had opened for receiving funds under prior permission order, with this, if you are still receiving funds under the PP order also. If you no longer receive funds under the PP order, you may keep that account as additional utilisation account, if necessary. But, while filing annual return, you may have to furnish details of transactions made during the year in both the accounts. So, you may decided now, whether to have one unified account or two accounts. Even if there are for different projects, an organisation is supposed to receive foreign funds only through one FCRA bank account approved by the FCRA dept.
Dear Ravi,
As I understand that the prior permission number is different to permanent registration and both have to be separately filed. Next year you will not have this issue as you will be receiving FC on your permanent registration.
Would be glad to read other members comment on the same.