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Form 15CA and 15CB are now Forms 145 and 146: what changed on 1 April 2026

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In short

  • From 1 April 2026, Form 15CA became Form 145 and Form 15CB became Form 146, both under Rule 220 of the Income-tax Rules, 2026 (old Rule 37BB).
  • Form 145 has four parts: A for taxable remittances up to Rs 5 lakh a year, B and C for amounts above Rs 5 lakh, and D for non-taxable payments.
  • Not filing Form 145, or filing wrong details, can attract a penalty of up to Rs 1 lakh under Section 462 of the Income-tax Act, 2025.
  • A CA who gives wrong information in Form 146 faces a penalty of up to Rs 10,000 per certificate under Section 463.

Form 15CA is now Form 145 and Form 15CB is now Form 146. The switch took effect on 1 April 2026, when the Income-tax Rules, 2026 replaced the 1962 Rules. The purpose is unchanged. Before money goes to a non-resident, the payer tells the tax department what is sent and how it was taxed.

For NRIs, these forms matter most when you send money out of an NRO account or receive payments from India. Banks will not release a taxable remittance without the Form 145 acknowledgement.

What changed on 1 April 2026

The forms were renumbered and moved to the new law. The underlying logic, including the Rs 5 lakh threshold, is broadly the same.

Item Before 1 April 2026 From 1 April 2026
Remitter’s declaration Form 15CA Form 145
CA certificate Form 15CB Form 146
Rule Rule 37BB, Income-tax Rules, 1962 Rule 220, Income-tax Rules, 2026
TDS on payments to non-residents Section 195, 1961 Act Section 393(2), 2025 Act
Assessing Officer certificate Sections 195(2), 195(3), 197 Section 395(1) and (2)
Penalty on remitter Section 271-I Section 462
Penalty on accountant Section 271J Section 463
Lower TDS application Form 13 Form 128

A few practical details are new or stricter:

  • UDIN on Form 146. The department’s FAQs say the 18-digit UDIN supports authenticity checks. Practitioners report that a Form 146 without one is treated as invalid.
  • Withdrawal window. Form 145 and Form 146 can be withdrawn within 7 days of submission. Neither can be edited after filing.
  • Linked forms. Withdrawing a Part C Form 145 also marks the linked Form 146 as withdrawn.
  • Treaty documents. Where a treaty rate is claimed, the supporting set is now the Tax Residency Certificate plus Form 41, which replaced Form 10F.

The four parts of Form 145

You choose one part per remittance. The Rs 5 lakh test looks at the total of such remittances in the tax year, not just the single payment.

Part When it applies CA certificate?
A The payment is taxable, and the year’s total is Rs 5 lakh or less No
B Taxable, total above Rs 5 lakh, and you hold an Assessing Officer certificate or order under Section 395 No
C Taxable, total above Rs 5 lakh, and no Assessing Officer certificate Yes, Form 146
D The payment is not taxable in India No

Part A

Use it for small taxable remittances. A typical case is an NRI sending Rs 2 lakh of NRO interest, already taxed, with nothing else sent that year.

Part B

Use it when the tax officer has fixed the rate in advance. For NRIs this usually follows a successful lower TDS application in Form 128, for example on a property sale.

Part C

This is the common case for NRO repatriation above Rs 5 lakh. Your CA files Form 146 first. You then file Part C and quote its acknowledgement number, and the portal pre-fills the details.

Part D

Use it when the remittance is not chargeable to tax at all. Some payment types do not need Form 145 at all. The department’s FAQs list three broad exemptions:

  • individual remittances that need no RBI approval, such as under the Liberalised Remittance Scheme;
  • payments by an IFSC unit;
  • payment types on a specified list of RBI purpose codes.

The old Rule 37BB list included non-residents’ remittances for family maintenance and savings, and personal gifts. Check the current Rule 220 list with your bank before relying on it.

Your bank decides in practice which part it accepts for an NRO transfer. Many ask for Part C with Form 146 for any meaningful amount, even when you believe tax is fully settled.

When you need a CA certificate

You need Form 146 only when all three conditions are met:

  1. the payment is chargeable to tax in India;
  2. the total of such remittances in the tax year exceeds Rs 5 lakh;
  3. you do not have an Assessing Officer certificate under Section 395.

The CA certifies how the income is taxed under the Act and under any treaty, the TDS deducted and the net amount being sent. The certificate carries the CA’s PAN, membership number, firm registration number and UDIN. Fees vary; a property sale with capital gains workings costs more than a plain interest remittance.

Which form for older remittances

The date of the remittance decides the form, not the date the income arose.

  • A remittance made on or before 31 March 2026 used Form 15CA and 15CB. Those filings remain valid for that remittance.
  • A remittance made on or after 1 April 2026 needs Form 145 and, if required, Form 146. Old 15CA/15CB forms are not accepted.

There is a wrinkle for income earned in 2025-26 but sent abroad after 1 April 2026. Practitioners read the rules as requiring the new forms for reporting. The tax itself is worked out under the 1961 Act, which governs that earlier year. Ask your CA to state this clearly in Form 146.

Penalties for getting it wrong

The penalty for not furnishing Form 145, or furnishing inaccurate details, is up to Rs 1 lakh under Section 462 of the 2025 Act. In practice the bank will also refuse to process the remittance.

A CA who certifies wrong information in Form 146 can face a penalty of up to Rs 10,000 per certificate under Section 463. If TDS was not deducted or was short-deducted, the payer can be treated as in default and charged interest.

How to file, step by step

  1. Log in to the e-filing portal at incometax.gov.in with your PAN.
  2. For Part C, add your CA under My Account, then Authorised Partners. Wait for the CA to file and e-verify Form 146.
  3. Go to e-File, then Income Tax Forms, then the forms under the Income-tax Act, 2025, and pick Form 145.
  4. Select the tax year and the correct part. You cannot change the part after submission.
  5. Enter remitter, recipient, amount, purpose code, nature of income and TDS details. For Part C, enter the Form 146 acknowledgement number.
  6. Preview and e-verify with EVC or a digital signature. Download the acknowledgement.
  7. Give the acknowledgement, Form 146 and your bank’s Form A2 to the bank before the money is sent.

Worked example

Meera lives in London. In tax year 2026-27 she wants to send three amounts from her NRO account to her UK account.

Date Amount Running total in the year Part of Form 145
May 2026 Rs 1,50,000 (taxed NRO interest) Rs 1,50,000 A
August 2026 Rs 2,50,000 (taxed rent) Rs 4,00,000 A
January 2027 Rs 40,00,000 (flat sale proceeds) Rs 44,00,000 C, with Form 146

The first two stay within Rs 5 lakh: Rs 1,50,000 + Rs 2,50,000 = Rs 4,00,000. Part A is enough.

The January remittance takes the total to Rs 4,00,000 + Rs 40,00,000 = Rs 44,00,000. That crosses Rs 5 lakh, so she needs Form 146 and Part C. If she had obtained a lower TDS certificate on the sale, she could have used Part B instead.

Common mistakes

  • Filing after the money has gone. Form 145 must be filed before the remittance.
  • Choosing the wrong part. The part is locked once submitted, so a mistake means withdrawing within 7 days and refiling.
  • Ignoring the yearly total. Part A applies only while the year’s running total stays at Rs 5 lakh or less.
  • Reusing a Form 146. The department’s FAQs say one Form 146 can be used for only one Form 145 Part C. Each new remittance that needs a CA certificate needs a fresh Form 146.
  • Mismatched figures. Amounts in Forms 145, 146 and A2 must agree, or the bank returns the file.
  • Claiming a treaty rate without Form 41. The CA needs your TRC and Form 41 to certify a treaty rate.

Checklist before you go to the bank

  • PAN, passport and proof of NRI status
  • Source proof for the money (sale deed, rent agreement, interest certificates)
  • TDS certificates and, for property, the capital gains computation
  • TRC and Form 41 if a treaty rate is claimed
  • Form 146 with UDIN (for Part C) and the Form 145 acknowledgement
  • Bank’s Form A2 or NRO-to-NRE transfer declaration
  • Recipient bank details abroad

What to do next

Sources

This guide explains the rules as they stood on 25 October 2026. It is general information, not tax, legal or financial advice. Rules change, and individual cases have exceptions, so confirm your position with a chartered accountant before acting. Spotted an error? Tell us and we will correct it.