Is Form 15CB Required for Import Payments? New Form 146 Rules and Exemptions

Is Form 15CB required for import payments? This is a common question for Indian companies purchasing machinery, raw materials, equipment, finished goods and other products from foreign suppliers.

The general answer is no for ordinary non-taxable imports of goods that qualify for the prescribed import-remittance reporting exclusions. However, the actual taxability of the payment, nature of the purchase and supporting contractual arrangements must be examined before deciding whether Chartered Accountant certification is required.

Important Update – October 2026: Form 15CB has been replaced by Form 146, and Form 15CA has been replaced by Form 145 for relevant remittances from 1 April 2026 under the Income-tax Act, 2025 and Income-tax Rules, 2026.

Rule 220(3) expressly includes specified import-related RBI purpose codes in the reporting exclusions for payments that are not chargeable to income tax in India. These include advance payments against imports and settlement of import invoices.

EzyBiz India Consulting LLP provides foreign-remittance taxability reviews, Form 145 filing, Form 146 CA certification and international tax advisory for Indian importers, multinational subsidiaries, manufacturers and businesses making overseas payments.

For assistance, call +91 98992 17778 or email anil@ezybizindia.in.

Explore our Form 145 and Form 146 Filing Services in India for transaction-specific professional assistance.

Is Form 15CB Required for Payment for Purchases?

General Rule for Ordinary Import of Goods

Under the earlier Form 15CA and Form 15CB framework, an ordinary purchase of goods from a foreign supplier generally did not require Form 15CB where the payment was not chargeable to income tax in India and qualified for a prescribed reporting exclusion.

Purchasing goods from an overseas supplier did not by itself establish an Indian income-tax liability.

Why the Nature of the Payment Matters

The underlying transaction must be examined before deciding whether a certificate is required. A commercial invoice described as a purchase may include royalties, technical services, software licences, financing charges or other components having different income-tax consequences.

The actual contractual rights and obligations are more important than the invoice heading alone.

Difference Between Import Payments and Taxable Remittances

An ordinary payment for imported goods may be outside Indian income-tax chargeability. In contrast, a payment containing taxable income such as royalty, interest or technical service fees may require withholding-tax and reporting analysis.

Accordingly, there is no universal exemption merely because the payment is described as an import.

Form 15CB Rules Applicable Before April 2026

Section 195 of the Income-tax Act, 1961

Section 195 governed withholding tax on specified payments chargeable to income tax in India and made to non-residents or foreign companies.

The chargeability of the underlying income was a fundamental consideration when determining the applicable withholding-tax requirement.

Rule 37BB and Foreign Remittance Reporting

Rule 37BB prescribed the information-reporting framework relating to Form 15CA and Form 15CB, including exclusions for specified remittance purposes.

Import-related purpose codes were included among the prescribed categories for qualifying non-chargeable payments.

When Form 15CB Certification Was Necessary

Form 15CB generally applied where the payment was chargeable to income tax in India, the payment or aggregate exceeded Rs. 5 lakh during the financial year, and the taxpayer followed the Chartered Accountant certification route.

The amount of an import invoice alone was insufficient to determine whether Form 15CB was required.

Read our Form 15CA and Form 15CB applicability guide for the earlier reporting framework.

What Changed From Form 15CB to Form 146?

New Form 146 Under the Income-tax Act, 2025

From 1 April 2026, Form 146 became the prescribed Accountant’s certificate corresponding to the earlier Form 15CB.

Form 146 is used for relevant taxable payments requiring certification by an eligible Chartered Accountant.

Form 145 Replaces Earlier Form 15CA

Form 145 is the current remitter declaration corresponding to the earlier Form 15CA. The applicable Part A, B, C or D depends on chargeability, the prescribed threshold, relevant certificates and reporting exclusions.

See our Form 145 Filing Guide – Parts A, B, C and D.

How Importers Should Apply the New Rules

For remittances from 1 April 2026, Indian importers should first determine whether the payment is chargeable to Indian income tax. They should then examine Rule 220 of the Income-tax Rules, 2026 to determine whether Form 145 or Form 146 is necessary.

Our Form 145 and Form 146 vs Form 15CA and Form 15CB comparison explains the transition.

Rule 220 Exemptions for Import Payments

Import-Related RBI Purpose Codes

Rule 220(3) provides specified reporting exclusions for payments that are not chargeable to income tax in India. The notified list expressly includes the following import-related RBI purpose codes:

RBI purpose code	Nature of remittance
S0101	Advance payment against imports
S0102	Payment towards import – settlement of invoice
S0103	Imports by diplomatic missions
S0104	Intermediary trade
S0190	Imports below Rs. 5 lakh – specified Exchange Control Department use

The reporting exclusion should be applied only where the transaction is not chargeable to tax in India and falls within the relevant prescribed category.

Consult the official Rule 220 of the Income-tax Rules, 2026 for the statutory list and conditions.

When the Import Reporting Exclusion Applies

Where an Indian business makes a payment exclusively for an ordinary import of goods, the amount is not chargeable to Indian income tax and the payment falls within the specified import purpose code, Form 145 reporting is ordinarily not required under Rule 220(3).

Consequently, Form 146 certification is also ordinarily unnecessary for that payment.

Why Exemptions Must Be Applied Carefully

The statutory exclusion depends on the actual transaction and its taxability. A purpose code should not be selected solely to avoid reporting requirements.

Importers should examine the invoice, agreement, nature of consideration and applicable RBI classification before concluding that an exemption is available.

Form 146 for Advance Payments Against Imports

Advance Payment Before Shipment

Indian importers frequently make advance payments to foreign suppliers before goods are manufactured, dispatched or delivered.

Such payments may qualify under RBI purpose code S0101 where they genuinely represent advance consideration for imports.

When Advance Import Payments Are Exempt

If the payment is solely for the import of goods, is not chargeable to income tax in India and satisfies the prescribed import-purpose classification, Form 145 and Form 146 are ordinarily unnecessary.

Documents for Advance Import Payments

Relevant documents may include the pro forma invoice, purchase order, supplier agreement, advance payment terms, description of goods, banking instructions and applicable import documentation.

Separate FEMA and authorised dealer requirements may apply to advance import remittances.

Form 146 for Settlement of Import Invoices

Payment After Goods Are Imported

An Indian importer may settle an invoice after goods are shipped, received or cleared through Customs.

Where the payment represents ordinary non-taxable consideration for imported goods and satisfies the relevant conditions, RBI purpose code S0102 may apply.

Payments Made Against Bills of Entry

The Bill of Entry, invoice, purchase agreement and banking particulars help establish the nature of the import transaction.

These documents may support the remitter’s position that the payment relates to ordinary goods purchased from an overseas supplier.

Delayed Settlement of Import Invoices

Where payment is delayed, the importer should determine whether additional consideration such as interest or financing charges is payable.

Such additional amounts may require taxability analysis separate from the principal purchase price.

Import of Machinery and Capital Equipment

Purchase of Machinery From a Foreign Manufacturer

Consider an Indian company purchasing machinery worth Rs. 40 lakh from an overseas manufacturer.

If the consideration relates exclusively to ordinary goods, no taxable service, royalty or other income component arises, and the payment qualifies under the prescribed import reporting exclusion, Form 145 and Form 146 would ordinarily not be required.

Machinery With Installation and Commissioning

Suppose the overseas supplier provides machinery along with installation, commissioning or technical support.

The agreement should be examined to determine whether the additional services have separate tax consequences under Indian law or the applicable DTAA.

Equipment With Technology or Licence Rights

Some machinery contracts include intellectual property licences, technical know-how, access to proprietary processes or ongoing software rights.

These arrangements should be reviewed to determine whether any component represents taxable royalty, technical services or another form of income.

Mixed Contracts Involving Goods and Services

Identifying Separate Taxable Components

A single purchase agreement may contain both ordinary goods consideration and charges for consultancy, training, installation, software or technology rights.

The taxpayer should examine the contractual obligations, invoicing and relevant tax provisions before determining the reporting treatment.

Example of Machinery With Technical Support

Assume an Indian company purchases machinery for Rs. 30 lakh and separately pays Rs. 8 lakh for technical support.

The machinery payment may qualify for the ordinary import exclusion if not chargeable to tax. The technical-support component must be examined separately for taxability under domestic law and the applicable DTAA.

If the technical-support payment is taxable and the prescribed certification conditions are satisfied, Form 146 and Form 145 Part C may become necessary for that component.

Allocation Between Goods and Services

Where a contract contains multiple components, the correct tax treatment should be determined from the agreement, actual commercial substance and relevant evidence.

A contractual allocation should not automatically be accepted if it is inconsistent with the transaction’s real character.

Software, Royalty and Technology Payments

Software Acquired With Imported Equipment

Imported equipment may include embedded software or separately licensed software.

The nature of rights granted, contractual structure and applicable income-tax and treaty provisions should be examined before determining whether a taxable royalty component arises.

Royalty and Intellectual Property Payments

Payments for use of patents, trademarks, technical know-how and other intellectual property may involve royalty considerations.

Such payments should not automatically be classified as ordinary imports of goods merely because they form part of a wider purchase arrangement.

Technical Know-How and Foreign Consultancy

Where a foreign supplier provides technical know-how, design services or consulting support, the relevant payment may require separate examination under the applicable domestic provisions and DTAA.

Depending on taxability and the prescribed filing route, Form 146 certification may be relevant.

When Is Form 146 Required for Foreign Purchase Payments?

Taxable Payment Exceeding Rs. 5 Lakh

Form 146 generally applies where the relevant payment to a non-resident or foreign company is chargeable to income tax in India, the payment or aggregate exceeds Rs. 5 lakh during the tax year and the remitter follows the Chartered Accountant certification route.

Where No Prescribed Assessing Officer Certificate Is Available

Where the applicable Assessing Officer certificate or order under Section 395(1) or 395(2) has not been obtained, the remitter may need to follow the Form 146 and Form 145 Part C process where the prescribed conditions are satisfied.

Relationship Between Form 146 and Form 145 Part C

The eligible Chartered Accountant first files Form 146 after reviewing the taxability and supporting documents.

The remitter subsequently completes Form 145 Part C using the filed Form 146 acknowledgement.

Read our Form 146 CA Certificate guide for the certification process, documentation and professional fees.

When Is Form 146 Not Required?

Ordinary Non-Taxable Import of Goods

Where the payment represents ordinary non-taxable consideration for imported goods and qualifies for a Rule 220(3) import-purpose reporting exclusion, Form 146 is ordinarily not required.

Taxable Payment Within the Prescribed Threshold

Where the payment is chargeable to Indian income tax but the relevant amount or aggregate does not exceed Rs. 5 lakh during the tax year, Form 145 Part A generally applies without Form 146 certification.

Taxable Payment Supported by an Assessing Officer Certificate

Where the relevant taxable payment exceeds Rs. 5 lakh and the prescribed Assessing Officer certificate or order supports filing Form 145 Part B, a separate Form 146 certificate is not required for the same reporting obligation.

The appropriate reporting route should be determined before obtaining CA certification.

Form 145 and Form 146 Decision Table for Importers

Taxable and Non-Taxable Payment Classification

The first step is determining whether the amount payable to the overseas supplier is chargeable to income tax in India.

Only after reviewing the taxability should the importer determine the applicable reporting route or exemption.

Applicable Form Based on Taxability and Certificates

Situation	Applicable reporting	Form 146
Ordinary non-taxable import qualifying under S0101 or S0102	No Form 145 under applicable exclusion	Not required
Taxable payment or aggregate up to Rs. 5 lakh	Form 145 Part A	Not required
Taxable payment above Rs. 5 lakh with prescribed AO certificate	Form 145 Part B	Not required
Taxable payment above Rs. 5 lakh following CA certificate route	Form 146 followed by Form 145 Part C	Required
Non-taxable payment not qualifying for a Rule 220(3) exclusion	Form 145 Part D	Not required

The table provides a general decision framework and should be applied to the actual transaction facts.

Effect of the Rs. 5 Lakh Threshold

The Rs. 5 lakh threshold is relevant to the reporting route for taxable payments. It does not automatically create an income-tax exemption or remove withholding obligations.

The aggregate of relevant payments during the tax year must also be considered.

Documents Required for Import Remittance Review

Foreign Supplier and Purchase Documents

• Supplier’s legal name and address.
• Commercial invoice or pro forma invoice.
• Purchase order and purchase agreement.
• Description of goods and commercial terms.
• Currency, value and proposed payment date.
• Supplier banking information.

Import and Customs Documentation

• Bill of Entry, where applicable and available.
• Bill of Lading or Airway Bill.
• Packing list.
• Import documentation and IEC details, where relevant.
• Applicable RBI purpose code.
• Bank remittance request and supporting payment details.

Additional Tax and Service Documents

• Separate installation or technical-support agreement.
• Software and licence agreements.
• Royalty and intellectual property documentation.
• Interest and financing terms.
• Tax Residency Certificate, where treaty relief is claimed.
• Applicable withholding-tax computations.
• Relevant recipient declarations.

The final checklist depends on the type of goods, contractual arrangements and applicable banking or tax requirements.

Do Banks Require a CA Certificate for Import Payments?

Difference Between Statutory and Banking Requirements

Authorised dealer banks may request supporting documents to satisfy FEMA, KYC, transaction-verification and internal compliance requirements.

However, the bank’s documentary requirements should be distinguished from the legal question of whether Form 145 or Form 146 is prescribed under Rule 220.

What if the Bank Requests Form 146 for Ordinary Imports?

If the payment appears to qualify for the prescribed non-taxable import-remittance exemption but the bank requests Form 146, the importer should clarify whether the bank requires statutory Form 146 or other taxability documentation.

The importer should support the proposed tax position using the agreement, invoice, import documents and relevant statutory provisions.

FEMA and RBI Compliance Remain Separate

An exemption from Form 145 or Form 146 does not remove other applicable requirements under FEMA, import regulations, banking procedures or Customs laws.

Importers should comply with the authorised dealer’s documentary and remittance requirements independently of income-tax reporting.

Common Mistakes in Import Payment Certification

Assuming Every Foreign Purchase Requires Form 146

Form 146 is not mandatory merely because a payment is made overseas, the invoice is denominated in foreign currency or the amount exceeds Rs. 5 lakh.

The payment’s Indian taxability and prescribed reporting route must first be determined.

Ignoring Taxable Components in Purchase Agreements

Importers should not ignore embedded royalty, licence fees, financing charges, technical services or other potentially taxable components.

These may require examination separately from ordinary goods consideration.

Using Incorrect RBI Purpose Codes

The RBI purpose code should reflect the actual transaction. A code should not be used merely because it appears on the list of excluded remittances.

The importer should maintain supporting evidence for the payment classification and taxability conclusion.

Frequently Asked Questions on Form 15CB and Form 146 for Imports

Is Form 15CB Required for an Import Invoice Above Rs. 5 Lakh?

Not merely because the invoice exceeds Rs. 5 lakh. For qualifying ordinary non-taxable import payments under the earlier framework, Form 15CB was generally unnecessary.

For current remittances, the corresponding Form 146 requirement depends on Indian taxability and the applicable Rule 220 conditions.

Is Form 146 Required for Advance Payment to a Foreign Supplier?

Generally not where the advance represents non-taxable consideration for imports and qualifies under the prescribed S0101 reporting exclusion.

Separate FEMA and authorised dealer requirements may still apply.

Does Form 146 Apply to Imported Machinery With Technical Services?

The machinery and technical-service components must be examined according to the actual agreement and applicable income-tax and treaty provisions.

If a relevant component is taxable and the prescribed CA-certification conditions are satisfied, Form 146 and Form 145 Part C may be required for that component.

Foreign Remittance and CA Certification Services by EzyBiz India

Taxability Review for Import and Purchase Payments

EzyBiz India Consulting LLP assists Indian importers and businesses with determining whether an overseas purchase payment is chargeable to Indian income tax and whether any reporting or CA certification requirement applies.

Our review may include purchase agreements, invoices, service arrangements, treaty provisions and applicable import-related reporting exclusions.

Form 145 and Form 146 Filing Assistance

Our tax and regulatory services include:

• Review of import payment taxability.
• Assessment of Rule 220(3) reporting exclusions.
• Examination of RBI purpose codes.
• Review of royalty, technical services and software arrangements.
• DTAA and withholding-tax analysis.
• Form 146 CA certification, where applicable.
• Preparation and filing of Form 145.
• Coordination of relevant bank and FEMA documentation.

Contact Our Chartered Accountant Team

For an upcoming foreign purchase payment, share the invoice, agreement, country of the foreign supplier, amount, purpose of payment and proposed remittance date.

Our team can review the transaction and provide a professional quotation based on the relevant tax and filing requirements.

Mobile: +91 98992 17778

Email: anil@ezybizindia.in

Contact EzyBiz India Consulting LLP

306, 3rd Floor, Vishwa Sadan Building, District Centre, Janakpuri, New Delhi – 110058, India.

Mobile: +91 98992 17778

Email: anil@ezybizindia.in

WhatsApp: Chat with our tax team

Related Services and Supporting Guides

• Form 145 and Form 146 Filing Services in India
• Form 146 CA Certificate – Applicability and Documents
• Form 145 Filing – Parts A, B, C, D and Exemptions
• Form 15CA and Form 15CB – Earlier Framework
• Form 145 and 146 vs Form 15CA and 15CB
• FAQs on Form 15CA and Form 15CB
• Step-by-Step Filing Guide for Forms 15CA and 15CB

Official Regulatory References

• Income Tax Department – Rule 220 of Income-tax Rules, 2026
• Income Tax Department – Form 145 User Manual
• Income Tax Department – Form 146 User Manual
• Income Tax Department – Historical Form 15CA FAQs
• Income Tax Department – Historical Form 15CB FAQs
• Income Tax e-Filing Portal

Reviewed By: CA Anil Agrawal, Founder, EzyBiz India Consulting LLP.

Last Updated: October 2026

Disclaimer: This article provides general information regarding Form 15CB, Form 146 and the reporting requirements applicable to foreign purchase and import payments. The statutory requirements depend on the remittance date, nature of payment, Indian income-tax chargeability, applicable DTAA provisions, contractual terms, supporting documents and relevant reporting exclusions under the Income-tax Rules. Import-related exemptions should be applied only where the prescribed conditions are satisfied. Readers should obtain transaction-specific professional advice before determining withholding tax, claiming reporting exclusions or making foreign remittances. This article does not constitute a formal tax opinion or Chartered Accountant certificate. Income-tax compliance does not replace applicable FEMA, RBI, Customs or authorised dealer banking requirements. Laws, rules and portal procedures may change.