Guidance Note on filing of FCRA Annual Return (FC-4)

Many of SRRF Dialogue members would be involved in finalising their FC4 return. This year’s return has certain issues, which is creating a lot of confusion, amongst most NPOs. SRRF Dialogue is posting a para-wise Guidance to help members fill up their FC4 and comply.

S.No. FC-4 Particulars Comments
Para 1 Name Address, FCRA Reg. No. & Date Data is autopopulated from data maintained by FCRA Dept as per FCRA registration.
Para 2 Details of FC Receipts
(a) Brought forward FC This information needs to be typed and will not be autopopulated based on last year’s FC-4
  RECEIPTS  
(b)(i) Receipt – Intertest This should match with R&P
(b)(ii) Other Receipts Generally from sale of assets, etc.
(b)(iii) Income Tax refund trfd from non-FCRA Bank A/c  This is a new field and needs to be filled in, in case NPO has trfd TDS refund from non-FCRA to FCRA A/c.
(c) FC rec’d from foreign source during the FY
(i) Directly from a foreign source In most cases FC would be disclosed under this source only. 
(ii) as transfer from a local source  Not likely 
(d) Total FC (a+b+c) autopopulated (a)+(b)+(c)
Ensure this total agrees with R&P
(ii) (a) Donor-wise details of FC rec’d in form of a Table 
  Table has 7 columns, while all others are self-explanatory, col 5 needs special mention. Col 5 requires disclosure of ‘Purpose’ for which grant has been rec’d. This should align with the Purpose as specified in the FCRA registration. Generally Social, Educational or Economical. 
(ii) (b) Cumulative purpose-wise amount will be  Will be autopopulated according to disclosure in previous Table.
Ensure this total agrees with figure Para 2(d) above. 
Para 3 Details of Utilisation of FC
(a)   There is amajor problem in this Table, relating to Admin costs. If Admin costs of a project are included under individual project Utilisation costs column, then this will double Admin costs, as the Admin costs are also required to be separately disclosed under (ii) below the Table. Assumption by the Dept seems to be that Admin costs are not part of Project costs, and hence should not be included in the Utilisation cost of a Project.
If one includes Admin costs both under individual projects as well as under (ii) also, then Total costs will become higher than total utilisation under (iii). The Table does not accept it. Hence ideally do not include Admin costs under Utilisation column (8) of Table and disclose it under (ii) only. Problem arises that than unutilised balance under individual projects becomes higher by the amount of Admin costs not included under the projects.  To overcome this issue, one needs to reduce Admin costs from FC Receipts under col 6 of the Table.  
  Important: Since the above means that Total Receipts in this Table and as disclosed under Para 2 above do not match, a explaination in the form of reconciliation may be given alsong with Auditor’s Certificate.
3(a)(i) Utilisation for projects as per aims & objectives of the association Data will get autopopulated from Table under 3(a)
3(a)(ii) Total Admin Exps. This figure needs to be typed and should be separately worked out. 
3(a)(iii) Total Utilisation of FC This is auto-populated by adding figures in Col 8 under 3(a)(i) & (ii).
(b) Give details of all the assets capitalised and also included in Para 3(a) above. 
(ba)   Provide opening balance, additions, disposed and closing balance for each category of asset, as in FCRA Fixed Asset schedule. Ensure figures are matching with what is included in Bal Sheet. In which case the table in FC4, will not cross-tally as the Table does not include dep’n. Some experts are of the opinion, that only Gross Values should be disclosed, but then value does not match with Balance Sheet. Also some NPOs do not carry forward Gross Values, as they carry forward only WDVs.
(bb) Give details of Immovable properties @ 31-3-2025.  Make sure, values agree with Balance sheet.
(c) FC trfd to other associations before 29-9-2020 There is no clarity why this detail is being asked for, since NPOs would not be able to remember all the funds trfd to NPOs before 29-9-2020. What it should state details of funds trfd to NPOs in violation of S.7 during this year. Most likely all will fill Nil.
(d)  Total utilisation in the year (a+c) This is auto-populated figure adding 4(a)+4(c)
4 Details of unutilised FC
4(i) Total FC invested in FDs One has to give totals of all FDs here as per requirement. Ensure figures are in agreement with your FCRA R&P and FCRA Bal. Sheet.
4(ii) Balance of Unutilised FC, in cash/bank, at the end of the year
(a) Cash in Hand  
(b) FC designated A/c  
(c) Utilisation Bank A/cs  
(d) Total (a+b+c) This gets auto-populated by adding above three figures. Please compare this figure with unutilised figure in Table 3(a). These should match, if not go back and look into the reasons for the same.
     
4(iv) This should read 4(iii), but Form numbers it incorrectly as 4(iv) This is Table for working out carry forward of Admin Exps.
  A. b/f unspent part of allowable Admin Exps. Since this is the first year, when Admin exps have been allowed to be carried forward, most likely it should be Nil for almost all NPOs.
  B. Total FC rec’d during the year This is autopopulated, data considers FC rec’d+interest+Other Income under Para 2 above.
  C. Allowable Admin Exps. Of current FY (20% of B) This is autopopulated by system
  D. Total Admin Exps. Incurred during the current FY This is autopopulated by system, picking the data from Para 3(a)(ii)
  E. Admin Exps. Of current FY utilised out of A above. The system is designed, so that it first allows Admin exps to be set-off against b/f unspent balance. However choice is left to NPO
  F. Admin Exps of current year utilised out of C above Allows NPO to decide how much to utilise against current year’s allowable admin exp.
  G. Unspent part of C above available to be carried forward This is calculated by system
  H. Out of G above, amount to be carried forward to next FY Type the amount of Admin Exps. Not utilised out of G
  I. Reason for carry forward of unspent part allowable Admin Exps. To next FY Give reasons, if some part of Admin Exps. Is being carried forward.

Other columns are self-explanatory

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3 Responses to Guidance Note on filing of FCRA Annual Return (FC-4)

  1. Pagolu Srinivas says:

    Can a FCRA organisation give loan to staff for his daughter marriage and how it can be repaid and to which account it has to be paid

  2. Nasim Ansari says:

    Facing problems regarding FC4 filling.
    Can you handholding / help me?

  3. Lahu Gaikwad says:

    I am also interested

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