USD 1 MN NRO LIMIT / YEAR TAX COMPLIANCE Form 15CA & Form 15CB Now Forms 145 & 146 — 2026 Filing Guide Rs 5 Lakh 15CB Trigger A – D Declaration Parts 1 Apr 2026 New Forms Apply RENUMBERING UNDER THE INCOME-TAX ACT, 2025 Form 15CA — Declaration → Form 145 Form 15CB — CA Certificate → Form 146 The Classic Partners LLP · Chartered Accountants theclassicpartners.com · Andheri East, Mumbai · August 2026 195 → 393 TDS ON NON-RESIDENTS INCOME-TAX ACT, 2025 · RULES, 2026

Form 15CA and 15CB are the two compliance documents Indian banks demand before sending money abroad: Form 15CA is the remitter's online declaration about a payment to a non-resident, and Form 15CB is the Chartered Accountant's certificate confirming its taxability and the correct TDS. Without the acknowledgement, the bank simply refuses to process the transfer, which makes these forms the practical gateway for every foreign remittance — from an NRI moving property sale proceeds abroad to a company paying a foreign consultant.

The framework has just been through its biggest change ever: for remittances made on or after 1 April 2026, the same documents operate as Form 145 and Form 146 under the new Income Tax Act, 2025 — identical logic, new numbers and section references. This guide from The Classic Partners LLP, Chartered Accountants in Mumbai, explains who needs the forms, the Rs 5 lakh rule, the 2026 renumbering, the filing steps, and the penalties for getting it wrong.

What Are Form 15CA and 15CB and Why Do Banks Ask for Them?

Form 15CA declaration and Form 15CB Chartered Accountant certificate for foreign remittance
Declaration and certificate — the two documents behind every outward remittance

Form 15CA is a declaration filed by any person making a payment to a non-resident or a foreign company, furnishing the nature of the remittance and the tax deducted on it. Form 15CB is the certificate in which a practising Chartered Accountant verifies that taxability, applies the relevant treaty, and states the TDS rate. Both flow from Section 195 of the Income-tax Act, 1961 — now Section 393 of the Income-tax Act, 2025 — which requires tax to be deducted from any sum chargeable to tax that is paid to a non-resident.

Form 15CA — The Declaration

  • Filed by the remitter, online
  • States nature of payment and TDS
  • Four parts: A, B, C and D
  • Needed before the bank acts
  • Becomes Form 145 from 1 Apr 2026

Form 15CB — The CA Certificate

  • Issued by a practising CA, with UDIN
  • Certifies taxability and DTAA position
  • Required above Rs 5 lakh taxable
  • Feeds into Part C of the declaration
  • Becomes Form 146 from 1 Apr 2026

Banks sit at the enforcement point. An authorised dealer bank cannot execute an outward remittance covered by the rules until the customer produces the Form 15CA acknowledgement — and, for larger taxable payments, the Form 15CB certificate behind it. The forms therefore touch an enormous range of transactions handled under international tax practice: royalty and technical fee payments, foreign professional charges, NRO account repatriations, dividend and interest payouts, and settlement of inherited or gifted funds moving overseas.

What Changed for Form 15CA and 15CB From 1 April 2026?

From 1 April 2026, Form 15CA operates as Form 145 and Form 15CB operates as Form 146, prescribed under the Income-tax Rules, 2026 that accompany the new Income-tax Act, 2025. The Income Tax Department's own guidance titles the new declaration as "Form No. 145, earlier Form No. 15CA", which settles that this is a renumbering of the same instrument rather than a fresh compliance.

The legal map has shifted in three places, while everything a remitter actually experiences carries over unchanged — the Part A to Part D structure, the Rs 5 lakh threshold for the Chartered Accountant certificate, portal-based filing, and the bank's insistence on the acknowledgement. The new regime also pushes further into automation, with system-driven validation of PAN, remittance details, and taxability at the point of filing.

Particulars Up to 31 March 2026 From 1 April 2026
Remitter's declarationForm 15CAForm 145
CA certificateForm 15CBForm 146
Governing statuteIncome-tax Act, 1961Income-tax Act, 2025
TDS on non-residentsSection 195Section 393
Duty to furnish informationSection 195(6)Section 397(3)(d)
Penalty provisionSection 271-I — Rs 1 lakhSection 462 — Rs 1 lakh
RulesIncome-tax Rules, 1962 (Rule 37BB)Income-tax Rules, 2026
Structure and thresholdsParts A–D · Rs 5 lakh triggerUnchanged · Parts A–D · Rs 5 lakh
📋 Note: Forms 15CA and 15CB filed for remittances completed on or before 31 March 2026 remain valid, because each form covers the specific payment and date proposed in it. Any remittance made on or after 1 April 2026 needs Form 145 — and Form 146 where applicable — even if the invoice or agreement is older. A Form 15CB that was drafted but whose remittance never went through must be reissued as Form 146 before the bank will act.

When Are Form 15CA and 15CB Required — and When Are They Not?

Whether the forms apply, and which part of the declaration to use, depends on two questions: is the payment chargeable to tax in India, and how much taxable money has gone to non-residents during the financial year. The declaration splits into four parts.

Part When it applies CA certificate
Part ATaxable remittances where the aggregate during the financial year does not exceed Rs 5 lakhNot required
Part BTaxable remittances above Rs 5 lakh covered by a lower or nil deduction certificate or order from the assessing officer, obtained before paymentNot required
Part CTaxable remittances above Rs 5 lakh in the year — the mainstream caseForm 15CB / 146 mandatory; details pulled into the declaration
Part DRemittances not chargeable to tax in India at allNot required — remitter declares

On top of this, the Rule 37BB exemption list, carried into the 2026 rules, keeps a specified set of payments outside the forms altogether:

  • Import payments for goods — routine trade remittances against a bill of entry.
  • Personal travel and medical remittances — including treatment abroad and accompanying travel.
  • Education-related transfers — tuition, fees and maintenance for students overseas.
  • Gifts and family maintenance sent under the Liberalised Remittance Scheme.

The exemption applies to the listed purpose codes as such. The moment a payment is taxable, or does not fit a listed purpose cleanly, the 15CB applicability limit of Rs 5 lakh and the full declaration framework take over.

How Is TDS Calculated on a Payment to a Non-Resident?

TDS on foreign remittance under Section 195 — now Section 393 — has no monetary threshold: if the sum is chargeable to tax in India, tax must be deducted whatever the amount, at the rates in force. The remitter deducts at the rate under the Act or the rate under the applicable tax treaty, whichever is more beneficial, and treaty relief is available only when the non-resident supplies a Tax Residency Certificate and electronic Form 10F before the payment.

Two technical points decide most disputes. Surcharge and cess apply on top of the rates in the Act but not on treaty rates, which are all-inclusive. And where the Indian payer bears the tax so that the non-resident receives an agreed net amount, the payment must be grossed up before applying the rate. This is exactly the analysis a Form 15CB certificate documents: the character of the income, the DTAA article that governs it, the beneficial rate, and the tax actually deducted — so that the bank, the department, and the remitter all rely on one certified position.

How Do NRIs Use Form 15CA and 15CB for Repatriation?

For NRIs, the forms are the paperwork behind almost every repatriation of assets from India. Funds in an NRO account — whether from a property sale, rent, interest, inheritance, or gifts — can be moved abroad or to an NRE account up to USD 1 million per financial year, and the bank executes the NRO to NRE transfer only against the Form 15CA acknowledgement, supported by the Chartered Accountant certificate in Form 15CB where the taxable amount exceeds Rs 5 lakh. The certificate confirms that capital gains tax on a property sale, or tax on the underlying interest and rent, has been paid or provided for.

Resident individuals sending money abroad face a lighter touch. Personal remittances under the Liberalised Remittance Scheme for listed purposes such as education, travel, medical treatment, gifts, and family maintenance sit in the exemption list and need neither form — although banks collect TCS at 2 percent on LRS transfers above Rs 10 lakh a year from FY 2026-27. The forms are an income tax compliance; the remittance channel itself, including the USD 1 million route and the LRS, runs under FEMA, and both sets of rules must be satisfied for the money to move.

How Do You File Form 15CA and 15CB Online? Step-by-Step Process

The filing sequence below applies identically to Form 15CA and 15CB and to their successors, Form 145 and Form 146, on the e-filing portal.

  1. Determine taxability and the correct part. Classify the payment, check the exemption list, test chargeability to tax in India, and compute the year's aggregate taxable remittances to pick Part A, B, C, or D. Every later document depends on getting this classification right.
  2. Assemble the transaction file. Collect the invoice or agreement, the non-resident's details and PAN where available, the Tax Residency Certificate and Form 10F for treaty claims, and the bank's purpose code for the outward remittance.
  3. Assign the form to your Chartered Accountant. For Part C cases, add the CA on the e-filing portal through the "My CA" facility and assign the certificate, which allows the CA to file directly against your PAN.
  4. Obtain the Form 15CB certificate. The CA examines the documents, applies the Act and the treaty, and uploads the certificate with a UDIN. The certified figures then flow into the declaration.
  5. File the declaration and e-verify. Complete the applicable part of Form 15CA, pull in the certificate details for Part C, and e-verify with a digital signature or OTP. Download the acknowledgement immediately.
  6. Submit the acknowledgement to the bank. Hand the acknowledgement, the certificate, and the bank's A2 form to the authorised dealer, which verifies the set and releases the remittance under the stated purpose code.
  7. Deposit TDS and close the loop. Deposit the TDS on the foreign remittance by the due date, report the payment in the quarterly non-resident statement, and preserve the full trail — these remittances are routinely matched in assessments.

What Are the Penalties for Skipping or Wrongly Filing the Forms?

The direct penalty is Rs 1 lakh for each failure to furnish Form 15CA, or for furnishing inaccurate information — imposed under Section 271-I of the 1961 Act for remittances up to 31 March 2026, and under Section 462 of the Income-tax Act, 2025 thereafter. The indirect consequences usually cost more: where tax was deductible and was not deducted or deposited, the remitter is treated as an assessee in default with interest, and a business remitter loses the expense deduction until the tax is paid.

⚠️ Important: A Form 15CB certificate is only as good as the tax actually deducted and deposited behind it. Deduct at the certified rate, deposit within the due date, and report the payment correctly through TDS return filing in the quarterly non-resident statement — a mismatch between the declaration, the challan, and the TDS statement is the most common trigger for notices on foreign remittances. Fix classification doubts before the money moves, not after.

How Has Foreign Remittance Reporting Evolved in India?

Before 1991, sending money out of India was an exercise in permissions. The Foreign Exchange Regulation Act, 1973 treated foreign currency as a controlled resource, and a remitter typically needed a no-objection or tax clearance from the assessing officer before the bank would even look at the transaction — a manual process that could take weeks for a single payment.

Liberalisation rebuilt the system in layers. FEMA replaced FERA from June 2000 and freed current account payments, and certificate-based clearance gave way to self-declaration: the CBDT introduced electronically filed Forms 15CA and 15CB in 2009, restructured Rule 37BB in 2013, and rationalised it in 2015 with the Rs 5 lakh threshold, the four-part declaration, and an expanded exemption list for routine payments. The 2021 e-filing portal added online CA assignment, UDIN-tagged certificates, and the withdrawal facility, with the whole workflow running through incometax.gov.in.

The Income Tax Act, 2025 completes the modernisation. From 1 April 2026 the same framework runs as Form 145 and Form 146 under the Income-tax Rules, 2026, with sharper system validation at the filing stage and unchanged substance. Six decades of law now say one simple thing to every remitter: certify the tax first, and the money moves without friction.

Need Professional Help with Form 15CA and 15CB?
The Classic Partners LLP, Chartered Accountants in Andheri East, Mumbai, handles the complete remittance cycle — taxability and DTAA analysis, Form 15CB and Form 146 certification with UDIN, Form 15CA and Form 145 filing, bank coordination for NRI taxation and NRO repatriation cases, and TDS deposit and reporting. Reach us before your next remittance date.

Frequently Asked Questions About Form 15CA and 15CB

What is the difference between Form 15CA and Form 15CB?
Form 15CA is the remitter's own declaration to the Income Tax Department describing a payment to a non-resident, its nature, and the tax deducted on it, filed online before the bank processes the remittance. Form 15CB is a certificate issued by a practising Chartered Accountant that verifies the taxability of that payment, the DTAA position, and the correct TDS rate. The declaration comes from the person sending the money, while the certificate comes from the professional validating it. Form 15CB is needed only when the taxable remittance exceeds Rs 5 lakh in a financial year, after which its details feed into Part C of Form 15CA.
Is Form 15CB mandatory for all foreign remittances?
No. Form 15CB is required only where the remittance is chargeable to tax in India and the aggregate of such payments exceeds Rs 5 lakh in the financial year. Taxable remittances up to Rs 5 lakh need only Part A of Form 15CA, payments that are not taxable at all are declared in Part D, and remittances covered by a lower-deduction certificate from the assessing officer go into Part B. In addition, the rules exempt a specified list of payments — such as imports, personal travel, education-related transfers, and gifts remitted under the Liberalised Remittance Scheme — from both forms entirely.
What are Form 145 and Form 146?
Form 145 and Form 146 are the new numbers for Form 15CA and Form 15CB under the Income-tax Act, 2025 and the Income-tax Rules, 2026, applicable to remittances made on or after 1 April 2026. Form 145 keeps the familiar Part A to Part D structure of Form 15CA, and Form 146 remains the Chartered Accountant certificate with the same Rs 5 lakh trigger. The governing provision has moved from Section 195 of the 1961 Act to Section 393 of the new Act, but who files, when, and why remain unchanged — treat it as a renumbering rather than a new compliance.
Is Form 15CA required for transferring money from an NRO to an NRE account?
Yes. Banks treat a transfer from an NRO account to an NRE account or abroad as a remittance requiring Form 15CA, and Form 15CB where the taxable amount crosses Rs 5 lakh, because the move takes funds out of the taxable Indian pool. The transfer sits inside the overall limit of USD 1 million per financial year available for repatriation from NRO balances. The Chartered Accountant certifies that tax on the underlying income — such as property sale proceeds, rent, or interest — has been paid or provided for before the bank executes the transfer.
What is the penalty for not filing Form 15CA?
The penalty for failing to furnish Form 15CA, or for furnishing inaccurate information in it, is Rs 1 lakh per default — levied under Section 271-I of the Income-tax Act, 1961 for remittances up to 31 March 2026 and under Section 462 of the Income-tax Act, 2025 thereafter. The practical consequences bite even earlier: the bank will not process the remittance without the acknowledgement, and where tax was deductible but not deducted, the remitter also faces interest, treatment as an assessee in default, and disallowance of the expense in business cases.
Can Form 15CA be withdrawn after filing?
Yes. Form 15CA can be withdrawn on the e-filing portal within 7 days of submission, which helps when a remittance is postponed, the amount changes, or an error is discovered after filing. The withdrawal option lapses once the window closes or the bank has processed the payment against the acknowledgement, after which filing a fresh form with correct details is the only route. Each Form 15CA is valid for the specific remittance and proposed date mentioned in it, so a payment that does not go through as planned needs new forms before the bank will act.

The Classic Partners LLP

Chartered Accountants  ·  Andheri East, Mumbai
Led by CA Nainit Savla, ACA and ex-KPMG. With over 10 years of practice, the firm serves startups, corporates, NRIs, and families across Mumbai and overseas with income tax, GST, audit, NRI taxation, FEMA, and cross-border remittance compliance.

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