FAQs on Filing Form 15CA and 15CB – Forms 145 and 146 Update

Forms 15CA and 15CB were commonly used for reporting and certification of payments and remittances made to non-residents. This FAQ guide explains their earlier applicability, filing requirements, different parts of Form 15CA, Form 15CB certification and other practical issues relating to foreign remittances from India.

Important Update – Forms 15CA and 15CB Have Transitioned to Forms 145 and 146

The foreign-remittance reporting and CA certification framework earlier associated with Forms 15CA and 15CB has transitioned to Forms 145 and 146. This article has been retained as an informational FAQ resource because taxpayers, NRIs and businesses continue to search for guidance relating to Forms 15CA and 15CB.

For current filing requirements, CA certification, documentation and assistance with foreign remittances, please refer to our Form 145 and Form 146 Filing and CA Certification Services in India.

The reporting framework has now transitioned to Forms 145 and 146. Therefore, the FAQs below should be read in the context of the earlier Form 15CA/15CB framework, while taxpayers making current foreign remittances should refer to the applicable Forms 145/146 requirements.

Form 15CA and Form 15CB – Basic FAQs

Q1. How can money be remitted outside India?

Ans. Before making a payment or remittance outside India, the remitter should examine the nature and purpose of the remittance, its permissibility under FEMA/RBI regulations and whether the payment is chargeable to tax in India.

Under the earlier framework applicable up to 31 March 2026, information relating to specified payments to a non-resident or foreign company was furnished through Form 15CA and, where applicable, a Chartered Accountant’s certificate in Form 15CB was obtained.

However, Forms 15CA and 15CB were not required for every foreign remittance. Their applicability depended upon factors such as the nature of payment, taxability in India, prescribed exemptions and the amount of remittance.

For remittances made on or after 1 April 2026, the corresponding reporting and CA certification requirements are complied with through Form 145 and Form 146, respectively, under the Income-tax Act, 2025 and Income-tax Rules, 2026.

Q2. What is Form 15CA?

Ans. Form 15CA was the information/declaration furnished by a person responsible for making specified payments to a non-resident, not being a company, or to a foreign company under the Income-tax Act, 1961.

The form provided the Income Tax Department with information regarding the nature and amount of the remittance and its tax implications. Depending upon the nature, taxability and amount of the remittance, the appropriate part of Form 15CA—Part A, B, C or D—was required to be furnished.

Form 15CA was therefore not merely a declaration that tax had been deducted. Its applicability and the relevant part depended upon the circumstances of the particular remittance.

For remittances made on or after 1 April 2026, Form 145 is the corresponding form under the Income-tax Act, 2025.

Q3. What is Form 15CB?

Ans. Form 15CB was a certificate furnished by a practising Chartered Accountant in specified cases of payments to a non-resident or foreign company.

Under the earlier framework, Form 15CB was required to be filled where the payment or aggregate of payments during the financial year exceeded ₹5 lakh, the payment was chargeable to tax in India, and the prescribed certificate/order from the Assessing Officer had not been obtained.

While issuing Form 15CB, the Chartered Accountant examined matters such as the nature of the remittance, its taxability under the Income-tax Act, applicable provisions of the relevant Double Taxation Avoidance Agreement (DTAA), the applicable rate of TDS and the amount of tax required to be deducted.

Form 15CB was therefore not required merely because the remittance exceeded ₹5 lakh; the taxability and other prescribed conditions were also relevant.

For remittances made on or after 1 April 2026, Form 146 is the corresponding Chartered Accountant’s certificate under the new framework

Q4. What types of remittances were commonly covered under Form 15CA and Form 15CB?

Ans. Forms 15CA and 15CB were relevant to specified payments or remittances made to non-residents or foreign companies, subject to the nature of the payment, its taxability in India and the exemptions prescribed under the applicable rules.

Common remittance situations included:

1. Remittance from an Indian bank account to a foreign bank account.
2. Repatriation of eligible funds from an NRO account.
3. Transfer of eligible funds from an NRO account to an NRE account.
4. Salary or employment-related payments.
5. Interest on bank deposits.
6. Repatriation of principal amount of deposits.
7. Sale proceeds of immovable property.
8. Sale proceeds of shares, securities or mutual funds.
9. Rental income.
10. Business, professional, consultancy, royalty, interest and other permissible payments to non-residents.

However, Form 15CA and Form 15CB were not automatically required merely because a remittance was made outside India. Applicability depended upon the nature and taxability of the payment and the prescribed exemptions.

For remittances made on or after 1 April 2026, the corresponding reporting framework is through Form 145 and, where applicable, Form 146 under the Income-tax Act, 2025. The Income Tax Department describes Form 145 as the information form for payments to non-residents/foreign companies and Form 146 as the corresponding accountant’s certificate.

Q5. Can separate forms be required where a remittance contains amounts having different tax treatment?

Ans. Yes, depending upon the facts, separate reporting or documentation may be required where a proposed remittance contains amounts having different nature, purpose or tax treatment.

For example, a remittance may contain both:

• a principal amount which is not chargeable to tax; and
• an interest component which may be taxable in India.

The remitter should therefore identify each component correctly and determine its taxability and applicable reporting requirement separately. The authorised dealer bank may also require the remittance to be appropriately classified according to the relevant purpose code and supporting documents.

Accordingly, it should not be assumed that different forms 15CA and 15CB. were mandatorily required in every case involving taxable and non-taxable components. The requirement depended upon the nature and treatment of each component.

For current remittances, the same analysis should be undertaken while determining the appropriate reporting under Forms 145 and 146.

Q6. Which form was required to be filed first – Form 15CA or Form 15CB?

Ans. Under the earlier framework, where Part C of Form 15CA was applicable, Form 15CB was required to be filed first by the Chartered Accountant.

The acknowledgement number of the filed Form 15CB was then required while furnishing Part C of Form 15CA.

Accordingly, the usual sequence was:

Form 15CB → Part C of Form 15CA

Under the current framework applicable from 1 April 2026, where Part C of Form 145 applies, the Chartered Accountant first furnishes Form 146, after which the remitter files the relevant Part C of Form 145. The Income Tax Department specifically lists filing of Form 146 as a prerequisite for Part C of Form 145.

Q7. What were the different Parts of Form 15CA?

Ans. Under the earlier Form 15CA framework, the form was divided into four parts – Part A, Part B, Part C and Part D. The appropriate part depended mainly upon the taxability of the remittance, the aggregate amount involved and whether a certificate/order from the Assessing Officer or a Chartered Accountant had been obtained.

Part A: Applicable where the payment was chargeable to tax in India and the remittance or aggregate of such remittances did not exceed ₹5 lakh during the financial year.

Part B: Applicable where the payment was chargeable to tax, the remittance or aggregate exceeded ₹5 lakh, and the prescribed certificate/order had been obtained from the Assessing Officer.

Part C: Applicable where the payment was chargeable to tax, the remittance or aggregate exceeded ₹5 lakh, and a certificate in Form 15CB from a Chartered Accountant had been obtained.

Part D: Applicable in specified cases where the remittance was not chargeable to tax in India, subject to the exclusions prescribed under the rules.

From 1 April 2026, Form 145 replaces Form 15CA. Importantly, Form 145 also contains Parts A, B, C and D, broadly following the same structure. Under the current rules, Part B refers to the prescribed Assessing Officer certificate under section 395, while Part C applies where the required accountant’s certificate in Form 146 has been obtained.

Form 15CA/15CB Filing and Compliance FAQs

Q8. I am filing only Part A of Form 15CA. Do I also need to file Form 15CB?

Ans. No. Under the earlier framework, Form 15CB was not required where only Part A of Form 15CA was applicable.

Form 15CB was relevant for Part C of Form 15CA, generally where the payment was chargeable to tax in India, the remittance or aggregate remittances exceeded ₹5 lakh during the financial year, and an order/certificate from the Assessing Officer had not been obtained.

Under the current framework, the same broad principle continues: Form 146 is required for Part C of Form 145 and not for Part A.

Q9. What details are required to be filled in Form 15CB?

Ans. Form 15CB was a Chartered Accountant’s tax determination certificate and contained information relating to the remittance and its tax treatment.

The principal details included the particulars of the recipient, details and amount of the remittance, bank/remittance particulars, taxability under the Income-tax Act, applicability of the relevant DTAA, applicable TDS rate and details of the Chartered Accountant issuing the certificate.

Under the current framework, Form 146 broadly contains seven panels covering particulars of the remitter, remittee and remittance, taxability under domestic law, taxability under the applicable DTAA, TDS details and verification.

Q10. What details are required to be filled in Form 15CA?

Ans. The information required in Form 15CA depended upon whether Part A, Part B, Part C or Part D was applicable.

Generally, the form contained particulars of the remitter, particulars of the non-resident recipient, nature and amount of the remittance, relevant tax details and verification by the person furnishing the form. Where Part B applied, details of the Assessing Officer’s order/certificate were required, while Part C was linked with the corresponding Form 15CB issued by the Chartered Accountant.

The current Form 145 follows a similar structure. For Part C, information from Form 146 is pre-filled on the basis of the acknowledgement number of the Form 146 filed by the Chartered Accountant.

Q11. Can Form 15CA and Form 15CB be revised, cancelled or withdrawn after filing?

Ans. A filed Form 15CA could be withdrawn within seven days from the date of submission through the e-Filing portal.

A withdrawal facility was also introduced for Form 15CB, enabling the Chartered Accountant to withdraw the filed Form 15CB within the permitted period by recording the appropriate reason. ICAI’s guidance specifically referred to withdrawal within seven days of filing.

Where material particulars of a filed form were incorrect, it was generally preferable to withdraw the incorrect form, where the facility and prescribed time permitted, and furnish a fresh correct form rather than treat the original form as capable of ordinary editing.

For current Forms 145 and 146, taxpayers should follow the withdrawal/correction functionality available on the e-Filing portal at the relevant time rather than assuming that every procedural feature applicable to Forms 15CA/15CB continues unchanged.

Q12. What were the consequences of non-filing or incorrect filing of Form 15CA or Form 15CB?

Ans. Under the Income-tax Act, 1961, Section 271-I provided that where a person required to furnish information under Section 195(6) failed to furnish such information, or furnished inaccurate information, the Assessing Officer could impose a penalty of ₹1 lakh.

Therefore, the reference in the old article to simply “Section 271” should be replaced with Section 271-I.

This provision relates to the earlier Form 15CA/15CB framework. For remittances made on or after 1 April 2026, reporting is governed by the Income-tax Act, 2025 and Forms 145 and 146, and the applicable provisions under the new law should be considered.

Q13. Is Form 15CA compulsory even if the remittance is not taxable in India?

Ans. Not necessarily.

Under the earlier Rule 37BB, where a payment to a non-resident was not chargeable to tax in India, Part D of Form 15CA generally applied. However, no Form 15CA was required for certain exempt categories specified in Rule 37BB(3), including prescribed remittances by individuals and remittances covered by specified RBI purpose codes.

Therefore, it was incorrect to say that Form 15CA was never required merely because the remittance was non-taxable.

Under the current framework, Rule 220 of the Income-tax Rules, 2026 follows the same broad principle: Part D of Form 145 applies to non-taxable remittances unless the payment falls within the exclusions prescribed in Rule 220(3).

Q14. My bank is asking for Form 15CA even though the remittance is not taxable. What should I do?

Ans. First determine whether the remittance falls within the prescribed exemptions.

Under the earlier Rule 37BB, a non-taxable remittance could still require Part D of Form 15CA unless it fell within one of the exemptions contained in Rule 37BB(3).

If the remittance was specifically exempt from Form 15CA reporting, the remitter could provide the bank with appropriate supporting documents explaining the nature of the remittance and the applicable exemption. The bank may separately require documents for FEMA, RBI, KYC or internal compliance purposes.

For remittances on or after 1 April 2026, the equivalent analysis should be carried out under Rule 220 and Form 145.

Q15. Can Form 15CA be withdrawn once it is filed?

Ans. Yes. Under the earlier Form 15CA framework, a filed Form 15CA could be withdrawn within seven days from the date of submission through the e-Filing portal.

If an error was discovered, the withdrawal should therefore have been made within the permitted period wherever possible, followed by filing of the correct form.

For current remittances, Form 145 has replaced Form 15CA, and taxpayers should use the functionality and procedure prescribed for Form 145 on the current e-Filing portal.

Q16. Who can sign or e-Verify Form 15CA?

Ans. Form 15CA could be furnished by the taxpayer or through the applicable Authorised Signatory or Representative Assessee registered on the e-Filing portal.

The form could be e-Verified through the prescribed verification modes, including DSC or EVC, subject to the applicable e-Filing requirements. Where DSC-based verification was mandatory or the registered DSC was applicable, the form was required to be verified accordingly.

Under the current framework, Form 145 can similarly be used by the taxpayer, Authorised Signatory or Representative Assessee and is e-Verified through the modes available on the portal.

Q17. We have obtained a certificate/order under Sections 195(2), 195(3) or 197. Which form is required?

Ans. Under the earlier framework, where the taxable remittance or aggregate remittances exceeded ₹5 lakh and the prescribed order/certificate had been obtained from the Assessing Officer under Sections 195(2), 195(3) or 197, Part B of Form 15CA was applicable.

In such a case, Form 15CB was not required.

Under the current Income-tax Act, 2025 framework, where the relevant Assessing Officer certificate has been obtained under Section 395(1) or 395(2), Part B of Form 145 applies and Form 146 is not required.

Practical Foreign Remittance FAQs

Q18. My company has purchased an online database using a corporate credit card. Do we need to file Form 15CA and Form 15CB?

Ans. The use of a corporate credit card does not by itself determine whether Form 15CA or Form 15CB is required.

The nature of the payment must first be examined to determine whether the amount paid to the non-resident is chargeable to tax in India and whether the payment falls within any prescribed exemption.

If the payment was chargeable to tax and the prescribed conditions for Part C were satisfied, Form 15CB and Part C of Form 15CA could be required. Conversely, if the payment was not chargeable or fell within a prescribed exemption, the reporting requirement could be different. This follows from the structure of Rule 37BB, which bases the applicable part primarily on taxability, amount and prescribed exemptions, rather than the payment instrument used.

For payments made on or after 1 April 2026, the same analysis should be undertaken under Rule 220 and Forms 145/146.

Q19. I want to send a gift to my brother in the USA. Do I need Form 15CA and Form 15CB, or is a gift deed sufficient?

Ans. A personal gift remittance should not automatically be treated as requiring Forms 15CA and 15CB.

Under the earlier Rule 37BB(3), “remittance towards personal gifts and donations” under RBI purpose code S1302 was specifically included in the list of remittances for which information in Form 15CA was not required where the payment was not chargeable to tax in India.

Therefore, where the conditions of Rule 37BB were satisfied, neither Form 15CA nor Form 15CB was required merely for making the personal gift. The bank could, however, require a gift deed, source-of-funds evidence and FEMA/RBI documentation to establish the nature and permissibility of the remittance.

The position remains substantially similar under Rule 220 of the Income-tax Rules, 2026, which also specifically includes purpose code S1302 – remittance towards personal gifts and donations in its prescribed list.

Q20. We filed Form 15CB but did not file the corresponding Form 15CA. We later found that Form 15CB was incorrect. What should we do?

Ans. An incorrect Form 15CB should not be used for filing Part C of Form 15CA.

Where the withdrawal facility was available within the prescribed period, the Chartered Accountant could withdraw the incorrect Form 15CB and thereafter furnish a fresh and correct Form 15CB. ICAI confirmed that the e-Filing portal provided a withdrawal facility for Form 15CB within seven days of its filing.

A fresh Form 15CB would generate a fresh acknowledgement number, and that correct acknowledgement should be used for the corresponding Part C of Form 15CA. The Income Tax Department confirms that one valid Form 15CB acknowledgement is used for filing the corresponding Form 15CA Part C.

Q21. A resident has purchased an immovable property from an NRI and is making payment to the NRI’s NRO account. Are Forms 15CA and 15CB required?

Ans. The fact that payment is credited to the seller’s NRO account in India does not, by itself, decide whether Form 15CA/Form 15CB is required.

The relevant question under the earlier Rule 37BB was whether a payment was being made to a non-resident and whether the amount was chargeable to tax in India. Rule 37BB was framed in terms of payment to a non-resident or foreign company and did not provide a general exemption merely because the amount was credited to an NRO account in India.

Accordingly, in the case of purchase of property from an NRI, the buyer should separately determine the taxability of the payment, applicable TDS and the relevant Form 15CA/15CB requirement. Payment into an NRO account should not automatically be treated as sufficient reason for non-filing.

The same principle should be applied under current Rule 220 and Forms 145/146, which similarly regulate payments to non-residents.

Q22. We filed Form 15CB, but the bank later asked us to change the service/purpose code. If we file a fresh Form 15CB, do we need a fresh UDIN?

Ans. Yes. If a fresh Form 15CB is being issued with corrected particulars, a fresh UDIN should be generated for the fresh certificate. The UDIN relating to the earlier certificate should not be reused for the new certificate.

ICAI requires UDIN for certificates issued by practising Chartered Accountants and has prescribed separate procedures for revocation. Under the current ICAI framework, revocation of a UDIN is generally permitted only within 48 hours from its generation.

The withdrawal of Form 15CB from the Income Tax e-Filing portal and revocation of its UDIN are separate actions. ICAI had separately clarified the Form 15CB withdrawal facility on the e-Filing portal.

Under the new Form 146 framework, the Income Tax Department has introduced real-time UDIN verification through the ICAI API, making correct UDIN particulars particularly important.

Q23. Is it mandatory to quote the acknowledgement number of Form 15CA in Form 27Q?

Ans. Under the earlier Form 15CA framework, the prescribed TDS reporting requirements provided for quoting information relating to the corresponding Form 15CA in Form 27Q, where applicable. The requirement originated under the earlier reporting framework and Form 27Q continues to be the quarterly TDS statement for payments to non-residents.

However, this FAQ should now clearly distinguish the historical position from the current law.

For remittances made on or after 1 April 2026, Forms 145 and 146 replace Forms 15CA and 15CB, while Form 27Q continues under the Income-tax Act, 2025 for quarterly reporting of tax deducted on non-salary payments to non-residents. Therefore, taxpayers should follow the current Form 27Q schema/utility and the Form 145/146 framework applicable for the relevant tax year, rather than relying upon the old Form 15CA reference.

Current Form 145 and Form 146 Compliance

For remittances made on or after 1 April 2026, Forms 15CA and 15CB have been replaced by Forms 145 and 146 under the Income-tax Act, 2025. Businesses, NRIs and other remitters should therefore determine the current reporting and CA certification requirements before processing a foreign remittance.

Prepared By: EzyBiz India Consulting LLP – Chartered Accountants & Tax Advisors
Last Updated: August 2026

Disclaimer: This article is intended for general informational purposes and should not be treated as professional advice. Foreign remittance requirements may vary depending on the nature of payment, taxability, FEMA/RBI regulations, applicable DTAA and the facts of each case. Professional advice should be obtained before undertaking a remittance.