Foreign remittances made by residents to nonresidents have always been a sensitive area under Indian tax law due to their potential tax implications and the risk of revenue leakage. To ensure effective monitoring and tax compliance on such payments, the Income Tax law has historically mandated the furnishing of detailed information and certifications prior to remittance.‑furnishing of detailed information and certifications prior to remittance.
Under the Income Tax Act, 1961, this objective was achieved through Forms 15CA and 15CB, prescribed under section 195(6) read with Rule 37BB of the Income Tax Rules, 1962. With the enactment of the Income Tax Act, 2025, effective from 1 April 2026, the framework has been continued with certain procedural refinements. The new law introduces Form No. 145 and Form No. 146 as corresponding equivalents while retaining the substantive compliance philosophy.‑‑‑Tax Act, 2025, effective from 1 April 2026, the framework has been continued with certain procedural refinements. The new law introduces Form No. 145 and Form No. 146 as corresponding equivalents while retaining the substantive compliance philosophy.
This article explains the purpose of these forms, their statutory basis under the new Act, transitional issues, and key compliance relaxations.
Form 15CA functioned as a self-declaration by the remitter, furnishing information regarding:
Form 15CB was a certificate issued by a Chartered Accountant, certifying:
These requirements were statutorily anchored in section 195(6) of the Income Tax Act, 1961, and were essential for enabling banks and authorised dealers to process outward remittances.‑ and were essential for enabling banks and authorised dealers to process outward remittances.
The Income Tax Act, 2025 preserves the foreign remittance compliance framework within section 397(3)(d). The corresponding prescribed forms under the new law are:‑ax Act, 2025 preserves the foreign remittance compliance framework within section 397(3)(d). The corresponding prescribed forms under the new law are:
These forms are notified under the Income Tax Rules, 2026, ensuring continuity with structured compliance while modernising procedural aspects.‑ax Rules, 2026, ensuring continuity with structured compliance while modernising procedural aspects.
A key transitional clarification relates to forms filed under the old law. Forms 15CA and 15CB already submitted for remittances made on or before 31 March 2026 remain valid even after the new Act comes into force from 1 April 2026, provided that:
As per prevailing practice, where remittance is not completed within the proposed date specified in Form 15CA/15CB, fresh forms must be filed prior to processing the payment.
For remittances made on or after 1 April 2026, the following will apply:
Importantly, the substantive requirements remain unchanged—remitters must continue to ensure correct evaluation of taxability, application of DTAA benefits where relevant and appropriate deduction of tax at source.
The thresholds for filing information and obtaining a CA certificate are prescribed under Rule 220 of the Income Tax Rules, 2026. The rules retain thresholds broadly similar to those applicable under the earlier regime, ensuring minimal compliance disruption for taxpayers during transition.‑ those applicable under the earlier regime, ensuring minimal compliance disruption for taxpayers during transition.
A practical issue arises where remittance is made after 1 April 2026 for a liability that accrued before that date. The position clarified under the transition framework is:
This distinction ensures consistency with established principles separating procedural compliance from charging provisions.
Form No. 145 adopts a four-part structure, similar to erstwhile Form 15CA:
Key Compliance Improvement
Under the new framework, where Part B is filed based on an Assessing Officer’s certificate, Part C is not required. This eliminates duplication that existed earlier and reduces both effort and cost for taxpayers.
Form 146 mandates quoting of UDIN (Unique Document Identification Number). The UDIN enables:
Only those Form 146 submissions with a valid UDIN are accepted, strengthening the credibility of the compliance system.
A significant relaxation under the new regime is that where the remitter furnishes Part B of Form 145 along with an Assessing Officer’s certificate, Form 146 is not required. This reduces compliance burden and duplication, reflecting a taxpayer‑friendly approach under the Income‑Tax Act, 2025.
The transition from Forms 15CA and 15CB to Forms 145 and 146 under the Income Tax Act, 2025 represents an evolution rather than a disruption. While the core objective of safeguarding tax compliance on foreign remittances remains unchanged, procedural efficiency, reduced duplication, and enhanced digital verification mark notable improvements.
Taxpayers and professionals must familiarise themselves with the applicable cut‑off dates, form structures, and dual‑law application principles to ensure smooth compliance during and after the transition phase starting 1 April 2026.