Form 15CA and Form 15CB FAQs – Applicability, Filing, Exemptions and New Forms 145 and 146

Form 15CA and Form 15CB FAQs help Indian businesses, taxpayers and NRIs understand the earlier foreign-remittance reporting requirements, Chartered Accountant certification, withholding tax, exemptions and filing procedures under the Income-tax Act, 1961.

Important Update – October 2026: For applicable remittances made on or after 1 April 2026, Form 145 replaces earlier Form 15CA and Form 146 replaces earlier Form 15CB under the Income-tax Act, 2025 and Income-tax Rules, 2026. The answers below distinguish the historical framework from the current reporting requirements.

For professional assistance with current filings, visit our Form 145 and Form 146 Filing Services in India page.

EzyBiz India Consulting LLP assists with foreign-remittance taxability, TDS, DTAA analysis, Accountant’s certification and related regulatory compliance.

Contact: +91 98992 17778 | anil@ezybizindia.in

Basic FAQs on Form 15CA and Form 15CB

What Was Form 15CA?

Form 15CA was the prescribed information declaration furnished by a person responsible for making specified payments to a non-resident, not being a company, or to a foreign company.

The form reported particulars of the remittance, recipient, taxability and withholding tax under the earlier Income-tax Act, 1961 framework.

What Was Form 15CB?

Form 15CB was an Accountant’s certificate issued by an eligible Chartered Accountant for specified foreign remittances.

It involved examination of the nature of payment, relevant income-tax provisions, DTAA benefits and withholding-tax computation.

What Was the Difference Between Form 15CA and Form 15CB?

Form 15CA was furnished by the remitter, whereas Form 15CB was certified by a Chartered Accountant.

Form 15CB was not required for every Form 15CA filing. It was principally relevant where the prescribed Part C certification conditions applied.

For a comprehensive historical explanation, read our Form 15CA and Form 15CB guide.

FAQs on the Transition to Forms 145 and 146

Are Form 15CA and Form 15CB Still Applicable After 1 April 2026?

For relevant remittances made on or after 1 April 2026, the prescribed forms are Form 145 and Form 146 under the Income-tax Act, 2025 and Income-tax Rules, 2026.

Earlier Forms 15CA and 15CB remain relevant for historical remittances and compliance records governed by the earlier framework.

Which New Forms Replaced Form 15CA and Form 15CB?

Form 145 replaces Form 15CA as the remitter’s information declaration. Form 146 replaces Form 15CB as the prescribed Accountant’s certificate.

Read our Form 145 and 146 vs Form 15CA and 15CB comparison for the statutory transition.

What if an Invoice Relates to February 2026 but Payment Is Made in April 2026?

The procedural reporting requirements follow the law applicable on the remittance date. Accordingly, a payment made in April 2026 generally follows the new Form 145 and Form 146 framework.

However, taxability of income accrued in February 2026 may need to be examined under the Income-tax Act, 1961, which governed the earlier accrual period.

The applicable withholding position should be determined after considering the transitional provisions and relevant transaction facts.

FAQs on Form 15CA Applicability

Who Was Required to File Form 15CA?

Under Rule 37BB, the person responsible for making a specified payment to a non-resident or foreign company was required to examine the applicable Form 15CA reporting obligation.

The requirement depended on the taxability, nature and amount of the payment and the relevant statutory exceptions.

Was Form 15CA Required for Every Foreign Remittance?

No. Certain remittances were excluded from reporting under Rule 37BB(3).

For example, specific non-chargeable remittances by individuals and payments within prescribed remittance-purpose categories could qualify for exclusions, subject to the relevant conditions.

Was Form 15CA Necessary if No TDS Was Deductible?

Possibly. A non-chargeable payment could still require Part D of Form 15CA unless a prescribed reporting exclusion applied.

The absence of a withholding-tax liability did not automatically eliminate every reporting requirement.

FAQs on Form 15CB Applicability

Was Form 15CB Mandatory for Every Remittance Above Rs. 5 Lakh?

No. The relevant payment needed to be chargeable to income tax in India, exceed the prescribed aggregate threshold and fall within the CA-certification route.

If the prescribed Assessing Officer certificate supported Part B of Form 15CA, Form 15CB was not separately required for that reporting route.

Could Form 15CA Be Filed Without Form 15CB?

Yes. Form 15CA Part A, Part B and Part D did not require Form 15CB merely because they were being filed.

The certificate was relevant to the Part C route under the earlier framework.

Who Could Issue Form 15CB?

An eligible Chartered Accountant registered on the Income Tax e-Filing portal could certify Form 15CB after the taxpayer assigned the form to that CA.

The CA needed to satisfy the applicable portal-registration and Digital Signature Certificate requirements.

For current certification requirements, see our Form 146 CA Certificate guide.

FAQs on Form 15CA Parts A, B, C and D

When Was Form 15CA Part A Applicable?

Part A generally applied where the payment was chargeable to tax in India and the payment or aggregate of relevant payments did not exceed Rs. 5 lakh during the financial year.

When Were Form 15CA Parts B and C Applicable?

Part B applied where the taxable payment or aggregate exceeded Rs. 5 lakh and the prescribed Assessing Officer certificate or order under section 195(2), 195(3) or 197 was obtained.

Part C applied where the relevant taxable amount exceeded Rs. 5 lakh and an Accountant’s certificate in Form 15CB was obtained.

When Was Form 15CA Part D Applicable?

Part D related to payments not chargeable to income tax in India, where no prescribed reporting exclusion under Rule 37BB applied.

Historical reporting part	Principal condition	CA certificate
Part A	Taxable payment or aggregate up to Rs. 5 lakh	Not required
Part B	Taxable payment above threshold with AO certificate or order	Not required
Part C	Taxable payment above threshold with Form 15CB certificate	Required
Part D	Non-chargeable payment not excluded from reporting	Not required

For current reporting, refer to our Form 145 Part A, B, C and D applicability guide.

FAQs on the Rs. 5 Lakh Threshold

Was the Rs. 5 Lakh Threshold Applied Per Invoice?

No. The earlier reporting framework considered the amount or aggregate of the relevant remittances during the financial year.

Splitting payments into smaller invoices did not automatically remove the applicable reporting or certification requirement.

Did the Threshold Mean Payments Below Rs. 5 Lakh Were Tax-Free?

No. The threshold was relevant to the prescribed information-reporting route. It did not create a general exemption from income tax or withholding tax.

Taxability had to be examined independently.

Does the Rs. 5 Lakh Threshold Continue Under Form 145?

Yes. Rule 220 of the Income-tax Rules, 2026 retains a Rs. 5 lakh threshold for the prescribed distinction between Part A and the relevant Part B or Part C routes.

The threshold must be considered together with chargeability and the other statutory conditions.

FAQs on Foreign Remittance Exemptions

Was Form 15CA Required for Non-Taxable Remittances?

A payment not chargeable to Indian income tax could require Part D unless it fell within a prescribed Rule 37BB(3) reporting exclusion.

Were Personal Remittances Exempt From Form 15CA?

Some individual remittances qualified for exclusions, including qualifying transfers that did not require prior RBI approval under the prescribed conditions.

However, the nature and purpose of the transfer needed to be examined. Not every personal remittance was automatically exempt.

What Reporting Exemptions Apply From April 2026?

Rule 220(3) of the Income-tax Rules, 2026 provides the current reporting exclusions for specified non-chargeable payments.

These include qualifying categories identified in the rule, subject to their individual conditions.

For the statutory text, see Rule 220 – Income Tax Department.

FAQs on Import Payments and Overseas Services

Was Form 15CB Required for Import of Goods?

Not automatically. Ordinary purchases of goods from a foreign supplier were not necessarily chargeable to Indian income tax.

However, payments involving embedded royalty, technical services or other potentially taxable components required further review.

Read our Form 15CB for foreign purchase payments article.

Were Foreign Consultancy Fees Subject to Form 15CA and 15CB?

The reporting obligation depended on the actual nature of services, the amount of relevant payments, Indian taxability and applicable DTAA provisions.

Foreign consultancy payments were not automatically exempt merely because the consultant performed services outside India.

Were Software and Royalty Payments Covered?

Software licences, intellectual property payments, royalties and technology arrangements could require examination under the relevant domestic income-tax and treaty provisions.

The rights granted under the agreement and commercial substance of the transaction were important to the analysis.

FAQs on NRI Repatriation and Property Proceeds

Did NRIs Need Form 15CA for Overseas Transfers?

Depending on the source and taxability of funds, the applicable reporting requirements could arise for NRI transfers from India.

Remittances of eligible funds also required examination under FEMA and authorised dealer banking procedures.

What About Remittance of Property Sale Proceeds?

Property-sale proceeds could involve capital gains taxation, withholding-tax records, source-of-funds documents and applicable FEMA requirements.

The relevant Form 15CA reporting position depended on the transaction and the prescribed exclusions.

Were Inherited Funds Automatically Exempt?

No universal conclusion could be reached merely because funds were inherited.

The source and nature of the funds, applicable taxability, reporting exclusions and FEMA or banking conditions needed to be evaluated.

FAQs on the Filing Process

Which Form Was Filed First – Form 15CA or Form 15CB?

Where Part C of Form 15CA applied, the Chartered Accountant first filed Form 15CB.

The remitter then used the Form 15CB acknowledgement number to complete Form 15CA Part C.

Under the current framework, the corresponding sequence is Form 146 followed by Form 145 Part C.

Could Form 15CA Be Filed Online or Offline?

Yes. The earlier Income Tax e-Filing portal provided prescribed online filing and offline utility options.

The form still needed successful submission and verification before the remittance.

How Was Form 15CA Electronically Verified?

The earlier portal allowed the prescribed DSC or EVC verification methods, subject to taxpayer-specific requirements.

The remitter retained the acknowledgement for banking and compliance records.

Consult the official historical Form 15CA User Manual.

FAQs on Documents for CA Certification

What Documents Were Required From the Remitter?

Common requirements included PAN, TAN where applicable, legal name, address, authorised signatory details, bank particulars and information relating to the relevant remittance.

What Documents Were Required From the Foreign Recipient?

Depending on the transaction, documents could include the recipient’s name, address, tax identification details, country of residence, Tax Residency Certificate, Form 10F and relevant treaty declarations.

Were an Invoice and Agreement Mandatory for CA Review?

The Chartered Accountant ordinarily needed adequate evidence to establish the commercial and legal nature of the payment.

An invoice, service contract, licence agreement, purchase order or other relevant supporting material could form part of the review.

The exact documentation depended on the transaction.

FAQs on TDS and DTAA for Foreign Payments

Does Every Foreign Remittance Require TDS?

No. The withholding-tax obligation depends on whether the relevant amount is chargeable to Indian income tax and on the applicable legal and treaty provisions.

Can DTAA Benefits Reduce the Applicable Tax?

Yes, an applicable DTAA may affect taxability or withholding rates where the foreign recipient meets the relevant treaty eligibility and documentary requirements.

The appropriate treaty article and actual facts must be considered.

Was a Tax Residency Certificate Relevant for Form 15CB?

A Tax Residency Certificate was important supporting evidence where treaty relief was claimed.

Other information, including Form 10F and relevant declarations, might also have been required according to the applicable law.

FAQs on Errors, Withdrawal and Penalties

Could Form 15CA Be Withdrawn After Filing?

Yes. Under the earlier Form 15CA filing process, a submitted Form 15CA could be withdrawn within seven days from the submission date through the prescribed portal functionality.

For current Form 145 corrections or withdrawals, taxpayers should follow the functionality and instructions applicable to Form 145 rather than assuming the historical procedure continues unchanged.

What Was the Penalty for Incorrect Form 15CA Reporting?

Under Section 271-I of the Income-tax Act, 1961, failure to furnish the prescribed remittance information or furnishing inaccurate information under Section 195(6) could attract a penalty of Rs. 1 lakh.

The applicable consequence depended on the legal requirements and the particular default.

What if the Bank Requested a Form for a Non-Taxable Payment?

The remitter needed to examine whether Part D applied or whether a prescribed reporting exclusion was available.

Even where income-tax reporting was not required, the authorised dealer bank could separately request invoice, FEMA, KYC or other supporting documentation.

FAQs on Forms 145 and 146 Under the Current Framework

What Is the Current Equivalent of Form 15CA?

Form 145 is the corresponding declaration under the Income-tax Act, 2025.

It contains Parts A, B, C and D for the prescribed reporting situations.

See our current Form 145 filing and exemptions guide.

What Is the Current Equivalent of Form 15CB?

Form 146 is the corresponding Accountant’s certificate for relevant taxable payments made to non-residents and foreign companies.

It supports the prescribed Part C filing of Form 145.

See our Form 146 CA Certificate guide.

Is Form 146 Required When an Assessing Officer Certificate Is Available?

No. Where the prescribed certificate or order under Section 395(1) or 395(2) supports filing Form 145 Part B, a separate Form 146 certificate is not required for the same reporting obligation.

This distinction is expressly recognised under Rule 220.

Practical Examples and Form 145/146 Filing Assistance

Example – Taxable Foreign Consultancy Payment of Rs. 3 Lakh

Assume an Indian company proposes to pay Rs. 3 lakh to a foreign consultant, the payment is chargeable to tax in India and the relevant aggregate during the tax year does not exceed Rs. 5 lakh.

Under the current framework, Form 145 Part A generally applies, subject to the prescribed conditions.

Example – Taxable Foreign Payment of Rs. 12 Lakh

Assume an Indian business proposes a taxable payment of Rs. 12 lakh to a foreign service provider without the prescribed Assessing Officer certificate or order.

Where the Part C conditions apply, Form 146 is certified first by the Chartered Accountant, followed by Form 145 Part C.

How Can EzyBiz India Assist With Foreign Remittance Compliance?

EzyBiz India Consulting LLP provides professional assistance with:

• Form 145 applicability and selection of the correct reporting part.
• Form 146 Chartered Accountant certification.
• Foreign-remittance taxability and withholding-tax review.
• DTAA, Tax Residency Certificate and supporting documentation.
• Online filing and acknowledgement procedures.
• Related international tax and FEMA compliance advice.

For transaction-specific assistance, contact +91 98992 17778 or 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 145 Filing – Parts A, B, C, D and Exemptions
• Form 146 CA Certificate – Filing, Fees and Documents
• Form 15CA and Form 15CB – Earlier Framework
• Form 145 and 146 vs Form 15CA and 15CB
• Step-by-Step Filing Guide for Earlier Forms
• Form 15CB for Foreign Purchase Payments

Official Regulatory References

• Income Tax Department – Form 15CA FAQs
• Income Tax Department – Form 15CB FAQs
• Income Tax Department – Rule 220
• Income Tax Department – Form 145 User Manual
• Income Tax Department – Form 146 User Manual
• Income Tax e-Filing Portal

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

Last Updated: October 2026

Disclaimer: This FAQ article provides general information regarding the earlier Forms 15CA and 15CB under the Income-tax Act, 1961 and corresponding Forms 145 and 146 under the Income-tax Act, 2025 and Income-tax Rules, 2026. Reporting obligations and withholding-tax treatment depend on the remittance date, nature of payment, chargeability of income, relevant statutory provisions, applicable DTAA, supporting documents and prescribed reporting exclusions. Readers should obtain transaction-specific professional advice before making foreign remittances or claiming tax treaty benefits. The article does not constitute a formal tax opinion or Chartered Accountant certificate. Income-tax reporting does not replace applicable FEMA, RBI or authorised dealer requirements. Statutory provisions and portal procedures may change.