If you are making a payment or remittance from India to a non-resident or foreign company, you may have heard of Form 15CA and Form 15CB. From 1 April 2026, these forms have moved to a new numbering framework under the Income Tax Act, 2025.

The important change is:

The Income Tax Department confirms that Form 145 is the corresponding form to old Form 15CA, while Form 146 is the corresponding form to old Form 15CB. For remittances made on or after 1 April 2026, Forms 145 and 146 under the new framework apply.

However, Form 15CA and Form 15CB remain extremely important search terms because they continue to apply to the legacy framework and because businesses, NRIs, banks, tax professionals and international businesses still commonly use the old terminology.

This guide explains Form 145, Form 146, Form 15CA, Form 15CB, the ₹5 lakh threshold, Parts A to D, CA certification, TDS on foreign remittances, DTAA benefits, NRI remittances, the filing process, documents required and the transition from the old to the new system.

What Replaced Form 15CA and Form 15CB?

Form 145 replaces Form 15CA under the Income Tax Act, 2025.

Form 146 replaces Form 15CB and serves as the Chartered Accountant’s certificate for applicable taxable foreign remittances.

For practical purposes:

• Form 15CA → Form 145
• Form 15CB → Form 146

The Income Tax Department states that the corresponding provision under the Income Tax Act, 2025 is Section 397(3)(d).

The substantive compliance objective remains familiar: determine whether the payment to the non-resident is taxable in India, determine the applicable TDS, consider DTAA relief where applicable, and furnish the prescribed remittance information before the payment is made.

What Is Form 145?

Form 145 is the new foreign-remittance information form under the Income Tax Act, 2025 and Income Tax Rules, 2026.

It is the new form corresponding to Form 15CA under the Income Tax Act, 1961.

Form 145 is furnished by the person responsible for making the payment to a non-resident, not being a company, or to a foreign company, before the remittance is made, where the conditions of the applicable rules are satisfied.

The form enables the Income Tax Department to obtain information about the remittance, including:

• Remitter details
• Non-resident/payee details
• Nature of payment
• Amount of remittance
• RBI purpose code
• TDS details
• Bank and authorised dealer details
• Taxability information
• DTAA-related information, where applicable

The Income Tax Department’s current Form 145 guidance also confirms that the form is filed for each applicable remittance before the amount is remitted.

What Is Form 146?

Form 146 is the new Chartered Accountant certificate corresponding to old Form 15CB.

It is relevant where a payment to a non-resident or foreign company is taxable and the payment or aggregate payments exceed ₹5 lakh during the tax year, and the prescribed Assessing Officer certificate has not been obtained.

A Chartered Accountant examines the remittance and certifies relevant matters including:

• Nature of the remittance
• Taxability under the Income Tax Act
• Relevant tax provisions
• Tax liability
• Applicable TDS
• DTAA applicability
• Treaty article
• Tax Residency Certificate
• Permanent Establishment considerations where relevant
• TDS deduction details
• Accountant’s verification and UDIN

The uploaded Income Tax Department material specifically states that Form 146 enables the Chartered Accountant to examine the remittance with reference to chargeability provisions and DTAA provisions.

Form 145 vs Form 146 vs Form 15CA vs Form 15CB

This is the simplest way to understand the new framework:

Form 145 vs Form 15CA

Form 145 is the new equivalent/replacement for Form 15CA under the Income Tax Act, 2025.

Form 146 vs Form 15CB

Form 146 is the new equivalent/replacement for Form 15CB under the Income Tax Act, 2025.

Does Form 146 have to be filed for every Form 145?

No.

Form 146 is relevant to Part C of Form 145 where the prescribed conditions are satisfied.

Where the remitter has obtained the applicable Assessing Officer certificate and files Part B of Form 145, a Form 146 certificate is not required for that Part B route. The Income Tax Department specifically clarifies that Part B and Part C are separate routes.

When Does Form 145 Apply?

Form 145 is an event-based form. It is required for each remittance satisfying the conditions prescribed under Rule 220 of the Income Tax Rules, 2026.

The uploaded Income Tax Department material states that there is no separately prescribed time limit for filing Form 145, but it should be submitted before the remittance is made.

However, not every foreign remittance automatically requires Form 145.

The uploaded guidance identifies exceptions including:

• A remittance by an individual that does not require prior RBI approval, including specified Liberalised Remittance Scheme transactions;
• Remittances by a Unit of an International Financial Services Centre; and
• Remittances of the nature specified under the relevant RBI purpose code.

Therefore, the correct question is not simply:

• “Am I sending money outside India?”

The correct question is:

• “What is the nature of the remittance, is it taxable in India, what is the applicable Rule 220 treatment, and does an exception apply?”

Form 145 Parts A, B, C and D Explained

One of the most important improvements in the new framework is understanding which part of Form 145 applies.

Part A – Remittance Up to ₹5 Lakh

Part A applies where the remittance or aggregate of such remittances is chargeable to tax and does not exceed ₹5 lakh during the tax year.

Part A captures information such as:

• Remitter details
• Remittee details
• Remittance amount
• Bank details
• Proposed date
• Nature of payment
• RBI purpose code
• TDS details
• Aggregate remittance
• Declaration

The ₹5 lakh threshold is an important search and compliance issue for anyone researching Form 145 applicability or the old Form 15CA Part A.

Part B – Remittance Above ₹5 Lakh With Assessing Officer Certificate

Part B applies where:

• The remittance is chargeable to tax;
• The remittance or aggregate remittances exceed ₹5 lakh during the tax year; and
• The prescribed certificate/order from the Assessing Officer under Section 395(1)/395(2) has been obtained.

Part B includes details of the Assessing Officer certificate, including the certificate number, date, section, amount and TDS rate.

Part C – Remittance Above ₹5 Lakh With Form 146

Part C applies where:

• The remittance is chargeable to tax;
• The remittance or aggregate remittances exceed ₹5 lakh during the tax year; and
• A Chartered Accountant’s Form 146 certificate has been obtained.

Part C includes accountant details and information relating to taxability under the Income Tax Act and relief under the DTAA.

This is the section where the relationship between Form 145 and Form 146 becomes particularly important.

The Income Tax Department’s online process requires the Form 146 acknowledgement number before Form 145 Part C can be completed. Information from the CA’s Form 146 can then be prefilled into Part C.

Part D – Remittance Not Chargeable to Tax

Part D applies where the remittance is not chargeable to tax under the Act, subject to the exclusions prescribed under Rule 220.

It contains remitter, remittee, remittance and declaration details.

This is why the statement “the payment is not taxable, so no Form 145 is required” should not be made without checking the applicable rules and exceptions.

Form 145 Decision Guide

Use this simplified framework as a starting point:

Step 1: Are you making a payment/remittance to a non-resident or foreign company?

Step 2: Does the transaction fall within an applicable Rule 220 exception?

• Yes → Form 145 may not be required under that exception.
• No → Continue.

Step 3: Is the remittance chargeable to tax?

If taxable and up to ₹5 lakh:

• Form 145 – Part A

If taxable and above ₹5 lakh + Assessing Officer certificate:

• Form 145 – Part B

If taxable and above ₹5 lakh + CA certificate:

• Form 146 → Form 145 – Part C

If not chargeable to tax:

• Form 145 – Part D, subject to Rule 220.

This decision framework is based on the Form 145 structure prescribed in the Income Tax Department’s guidance and the uploaded Form 145 material.

When Is Form 146 Required?

Form 146 is relevant when the remittance:

• Is made to a non-resident or foreign company;
• Is chargeable to tax;
• Exceeds ₹5 lakh during the tax year, including the prescribed aggregate threshold; and
• The applicable Assessing Officer certificate has not been obtained.

The Chartered Accountant examines the transaction and provides the prescribed certificate.

The Form 146 documentation includes analysis of:

Taxability under Indian law

The CA considers the relevant provisions and determines the taxability of the payment.

DTAA relief

Where treaty relief is claimed, the relevant DTAA article, nature of payment, taxability and tax liability are examined.

TDS

The certificate includes the amount and rate of TDS and other relevant deduction details.

Form 146 and DTAA: Why Tax Residency Certificate Matters

A foreign remittance may be subject to tax under Indian domestic law, but the taxpayer may also examine whether relief is available under an applicable Double Taxation Avoidance Agreement (DTAA).

For claiming DTAA benefits, the Form 146 documentation identifies the Tax Residency Certificate (TRC) as a relevant document.

The Form 146 guidance also requires treaty-related information such as:

• DTAA article
• Nature of payment
• Taxability
• Tax liability
• Applicable treaty treatment

For business income, the documentation also contemplates a No Permanent Establishment (No PE) declaration from the recipient where applicable.

This makes the Form 146 + DTAA + TRC + TDS combination particularly important for international payments.

Documents Required for Form 145 and Form 146

The exact documents depend on the nature of the transaction, but the Income Tax Department material identifies several important documents.

Core transaction documents

• Invoice
• Agreement or contract
• Remittance details
• Remitter details
• Remittee details
• Bank details
• RBI purpose code

Tax and treaty documents

• Form 41
• Tax Residency Certificate (TRC), where DTAA relief is claimed
• No Permanent Establishment declaration for relevant business-income cases
• Assessing Officer certificate, where applicable
• Form 146, where Part C of Form 145 is applicable

The Form 145 document specifically lists invoices/agreements, AO certificates, Form 146, Form 41 and TRC among the relevant documentation.

How to File Form 145 Online

Form 145 can be filed through the Income Tax e-Filing portal.

The current Income Tax Department process is broadly:

• Log in to the Income Tax e-Filing portal.
• Go to e-File → Income Tax Forms → File Income Tax Forms.
• Select Forms as per Income Tax Act 2025.
• Search/select Form 145.
• Select the applicable Tax Year and filing mode.
• Select the relevant Part – A, B, C or D.
• Enter the required remitter, remittee and remittance information.
• Review the information.
• Proceed to e-Verify.
• Submit the form.
• Save the transaction ID and acknowledgement number.

The Income Tax Department currently supports both online filing and an offline utility for Form 145.

How to File Form 145 Part C With Form 146

This is where many taxpayers and businesses need to understand the sequence.

Step 1 – Assign a Chartered Accountant

The remitter assigns the CA through the e-Filing portal.

Step 2 – CA prepares Form 146

The CA examines the remittance, taxability, DTAA position and TDS details and files Form 146.

Step 3 – Form 146 is e-Verified

The Form 146 material states that the CA’s form is e-Verified using DSC.

Step 4 – Obtain the Form 146 acknowledgement number

After successful filing, the acknowledgement number becomes relevant to the Part C filing.

Step 5 – File Form 145 Part C

The remitter enters the acknowledgement number of Form 146 and reviews the information that is prefilled.

Step 6 – e-Verify and submit Form 145

The remitter verifies the details and completes submission.

The official Form 145 user manual confirms this Form 146 → acknowledgement number → Form 145 Part C workflow.

Can Form 145 Be Filed Offline?

Yes.

The Income Tax Department provides an Offline Utility for Form 145 and Form 146.

The uploaded Form 145 material explains that the offline process involves:

• Downloading the statutory forms utility;
• Selecting Form 145;
• Selecting the appropriate Part;
• Entering the required information;
• Validating the form;
• Generating the XML;
• Uploading the XML or bulk file;
• e-Verifying the submission.

For Part C, the Form 146 XML/JSON submitted by the Chartered Accountant may need to be imported into the utility.

The Income Tax Department has also enabled the common offline utility for Forms 145 and 146.

What Happens After Form 145 Is Filed?

After successful e-Verification, the taxpayer receives a Transaction ID and Acknowledgement Number.

The Form 145 material also states that the form is integrated with the Department’s ITBA system for risk profiling, analytics and backend verification. Transactions may subsequently be selected for verification based on identified risk parameters.

This makes accuracy especially important.

A mismatch between:

• invoice details,
• remittance amount,
• TDS,
• purpose code,
• bank information,
• recipient information and
• taxability

can create avoidable compliance issues.

Form 146 and UDIN

One important change under the new framework is the inclusion of UDIN – Unique Document Identification Number.

The uploaded Form 146 material states that UDIN is now mandatory for Form 146 and enables the authenticity of the CA certificate to be verified through an API link with ICAI.

Form 145 Part C also captures accountant-related information including:

• PAN of accountant
• Firm Registration Number
• UDIN

This creates greater traceability and authenticity for CA-certified foreign remittance transactions.

Form 145 and Foreign Remittance: What Businesses Should Watch

Form 145 compliance is particularly relevant for businesses making recurring or significant overseas payments.

Examples may include:

• Payments to foreign vendors
• Overseas consultancy
• Software and SaaS payments
• Technical services
• Royalty payments
• Cross-border professional services
• International service arrangements
• Foreign contractor payments
• Other payments to non-residents

The correct tax treatment depends on the nature of the payment, the recipient’s status, applicable domestic tax provisions, DTAA provisions and the specific circumstances.

Do not determine TDS merely by looking at the invoice description.

A payment described as “consultancy”, “software”, “subscription”, “royalty”, “technical services” or “professional fees” may require a detailed taxability analysis.

Form 145 and NRI Remittances

NRIs are another important audience searching for Form 145, Form 146, Form 15CA and Form 15CB.

However, it is important to distinguish between:

• Income-tax compliance for a payment to a non-resident/foreign company, and
• FEMA/banking compliance for movement or repatriation of funds.

They are related but are not the same compliance question.

For example, an NRI dealing with the sale of an Indian property may need to separately evaluate:

• Capital gains tax
• TDS
• Taxability of the transaction
• Repatriation rules
• FEMA requirements
• Bank documentation
• Applicable foreign-remittance reporting

Therefore, “Is Form 145 required for NRI property sale?” should not be answered in isolation. The exact nature of the payment and remittance needs to be examined.

Form 145 for NRI Property Sale and Repatriation

NRI property transactions frequently involve cross-border movement of funds.

Before repatriating funds outside India, an NRI should consider the complete compliance chain rather than looking only at Form 145.

Depending on the transaction, this may involve:

• Capital gains computation
• TDS compliance
• Tax payment
• Property documentation
• Bank/Authorised Dealer requirements
• FEMA compliance
• Income-tax remittance reporting
• DTAA considerations where relevant

For NRIs in the USA, UK, Canada, UAE, Singapore, Australia and other countries, the India-side tax and remittance analysis should be completed before the funds are transferred.

Form 15CA and Form 15CB: What Happened to the Old Forms?

The old forms have not become irrelevant overnight.

The Income Tax Department confirms that Form 15CA/15CB already submitted for remittances made before 31 March 2026 can continue to remain valid, provided the remittance took place on or before the date specified in the form. If the remittance was not completed within the relevant period, fresh forms may be required.

For remittances made on or after 1 April 2026, Forms 145 and 146 under the new Income Tax Act, 2025 framework apply.

This transition point is extremely important for anyone searching:

• Form 15CA applicability
• Form 15CB applicability
• Form 15CA vs Form 145
• Form 15CB vs Form 146
• Form 145 replacing Form 15CA
• Form 146 replacing Form 15CB
• New Form 15CA replacement
• New Form 15CB replacement
• Foreign remittance forms 2026
• Income Tax Act 2025 foreign remittance

What If the Liability Arose Before 1 April 2026 but Payment Is Made After 1 April 2026?

This is a particularly important transition question.

The Income Tax Department clarifies that the procedural requirement follows the law in force on the date of remittance, while the taxability of the underlying income is governed by the law applicable to the year in which that income accrued.

Therefore, the date of the actual remittance can be critical.

If a liability arose under the earlier framework but payment is made after 1 April 2026, both the underlying taxability and the procedural remittance requirements need to be separately evaluated.

Penalty for Non-Compliance With Form 145

The uploaded Form 145 guidance states that a person who fails to submit Form 145 or provides inaccurate information can be liable for a penalty of up to ₹1 lakh under Section 462 of the Income Tax Act, 2025.

This is why Form 145 should not be treated as a simple banking form.

It is part of the tax compliance framework for specified foreign remittances.

Penalty for Incorrect Form 146

The consequences also extend to the Chartered Accountant.

According to the uploaded Form 146 guidance, an accountant providing inaccurate information in Form 146 can be liable for a penalty of up to ₹10,000 for each certificate under Section 463 of the Income Tax Act, 2025.

This reinforces the importance of a proper tax determination before Form 146 is issued.

Can Form 145 or Form 146 Be Withdrawn?

Yes.

The uploaded Income Tax Department material states:

• Form 145 can be withdrawn within 7 days of submission.
• Form 146 can be withdrawn within 7 days of submission.

However, once Form 145 is submitted, it cannot simply be edited in place; the prescribed withdrawal mechanism needs to be followed.

Common Mistakes in Foreign Remittance Compliance

1. Assuming every foreign remittance needs Form 146

Form 146 is not automatically required for every outward remittance.

It is specifically relevant to the applicable Form 145 Part C route.

2. Treating ₹5 lakh as a general tax-free limit

The ₹5 lakh threshold is a form applicability threshold in the prescribed framework. It does not mean that income below ₹5 lakh is automatically tax-free.

3. Ignoring aggregate remittances

The rules refer to the remittance or aggregate of such remittances where applicable.

4. Ignoring DTAA documentation

If treaty relief is claimed, the relevant documents and treaty position need to be established.

5. Getting the RBI purpose code wrong

The purpose code is an important component of the remittance information.

6. Filing Form 145 before completing the required Form 146 process

For Part C, Form 146 needs to be filed by the CA first, after which the acknowledgement number is used for Form 145 Part C.

7. Using old 15CA/15CB terminology without checking the remittance date

For remittances from 1 April 2026 onward, taxpayers need to work with the new Forms 145/146 framework.

Form 145 vs Form 15CA: Key Difference

The biggest difference is not the basic commercial nature of the transaction.

The major change is the statutory framework and form numbering.

Old framework

Income Tax Act, 1961 → Rule 37BB → Form 15CA/15CB

New framework

Income Tax Act, 2025 → Rule 220 → Form 145/146

The Income Tax Department confirms that the new forms retain similar thresholds and substantially continue the foreign-remittance compliance mechanism under the new numbering structure.

Form 146 vs Form 15CB: Key Difference

Form 146 is the new CA certificate corresponding to Form 15CB.

The fundamental role remains familiar:

CA examines the foreign remittance → determines taxability → considers DTAA where relevant → determines TDS → certifies the prescribed details.

The new Form 146 additionally captures updated identification and authentication information, including PAN, Firm Registration Number and UDIN.

Form 145 and Form 146: A Practical Example

Suppose an Indian company is making a taxable payment to a foreign service provider.

The company should first determine:

• Who is receiving the payment?
• What is the exact nature of the payment?
• Is the income taxable in India?
• What is the applicable domestic tax provision?
• Is DTAA relief available?
• Is the payment/aggregate above ₹5 lakh?
• Is an Assessing Officer certificate available?
• If not, is Form 146 required?
• What TDS should be deducted?
• What information needs to be reported in Form 145?
• What documents need to be retained?
• What does the bank/Authorised Dealer require before processing the remittance?

Only after answering these questions should the appropriate Form 145 Part be selected.

Form 145, Form 146 and the Bank/Authorised Dealer

Foreign remittance compliance does not end with income-tax filing.

The remitter also needs to coordinate with the bank or Authorised Dealer (AD) handling the remittance.

The uploaded Form 145 material notes that the form contains bank/authorised dealer information, purpose code, BSR code and other remittance-related information. It also discusses changes designed to improve electronic delivery and reduce reconciliation problems between remitter information and the reporting performed by the authorised dealer.

This makes accurate and consistent reporting particularly important.

Form 145 and Form 146 Checklist

Before making a foreign remittance, consider the following:

• Identify the recipient and country of residence
• Identify the exact nature of the payment
• Determine whether the payment is taxable in India
• Check the applicable domestic tax provision
• Check whether DTAA relief is available
• Obtain TRC and other treaty documentation where applicable
• Determine the applicable TDS
• Check the ₹5 lakh threshold and aggregate remittances
• Determine the correct Form 145 Part
• Obtain Form 146 if Part C applies
• Verify the CA’s Form 146 acknowledgement number
• Complete Form 145
• e-Verify the form
• Keep the acknowledgement and transaction ID
• Coordinate with the bank/Authorised Dealer
• Retain supporting documents

Frequently Asked Questions About Form 145, Form 146, Form 15CA and Form 15CB

Q1. What is the ₹5 lakh threshold for Form 145?

For the applicable taxable-remittance categories, ₹5 lakh during the tax year is the key threshold distinguishing Part A from the higher-value Part B/Part C routes.

Q2. When is Form 146 required?

Broadly, Form 146 is relevant for taxable remittances exceeding ₹5 lakh during the tax year where the prescribed Assessing Officer certificate route is not being used and Part C of Form 145 applies.

Q3. Is Form 146 required if an Assessing Officer certificate has been obtained?

For the Part B route, no. The Income Tax Department distinguishes the AO-certificate route in Part B from the CA-certificate route in Part C.

Q4. When should Form 145 be filed?

It should be furnished before the remittance is made where the form is applicable.

Q5. Can Form 145 be filed online?

Yes. Form 145 can be submitted through the Income Tax e-Filing portal and an offline utility is also available.

Q6. Can Form 146 be filed online?

Yes. Form 146 can be filed through the e-Filing portal, and the CA uses DSC for e-Verification.

Q7. Is Form 15CA still relevant in 2026?

Yes, particularly for understanding the old framework, legacy transactions and transition rules. For remittances made on or after 1 April 2026, the new Forms 145 and 146 apply.

Q8. Is Form 15CB still relevant?

Yes, for legacy transactions and because it remains a major search term. For the new framework, the corresponding form is Form 146.

Q9. Does Form 145 apply to NRIs?

Potentially, depending on the nature of the payment/remittance and the applicable rules. NRI property sales and repatriation transactions should be evaluated together with tax and FEMA requirements.

Q10. What documents are required for Form 146?

Depending on the transaction, relevant documents can include the invoice/agreement, remitter and remittee information, TRC, Form 41, No PE declaration where relevant, remittance details and supporting tax information.

Q11. What is UDIN in Form 146?

UDIN stands for Unique Document Identification Number. It provides a mechanism for verifying the authenticity of the Chartered Accountant’s certificate.

Q12. What is the penalty for Form 145?

The uploaded Income Tax Department guidance states that failure to submit Form 145 or furnishing inaccurate information can attract a penalty of up to ₹1 lakh under Section 462.

Q13. What is the penalty for incorrect Form 146?

The uploaded guidance states that an accountant providing inaccurate information can face a penalty of up to ₹10,000 for each certificate under Section 463.

Final Takeaway: Form 145 and Form 146 Are the New Foreign Remittance Compliance Forms

The transition from Form 15CA and Form 15CB to Form 145 and Form 146 is one of the important procedural changes introduced with the Income Tax Act, 2025.

For remittances from 1 April 2026 onward, taxpayers should focus on:

Form 145 + Form 146 + Rule 220 + TDS + DTAA + TRC + RBI/AD requirements

At the same time, Form 15CA and Form 15CB remain important legacy search terms and should not be ignored, particularly while dealing with older remittances and understanding the transition.

The most important practical rule is simple:

Do not make a foreign remittance first and investigate tax compliance later. Determine taxability, TDS, DTAA eligibility and the correct Form 145/146 requirement before the payment is processed.

For businesses, NRIs, foreign vendors, startups, professionals and companies making regular cross-border payments, a transaction-specific review can prevent incorrect TDS, remittance delays, documentation gaps and avoidable tax exposure.

Dinesh Aarjav & Associates advises businesses, NRIs and individuals on Form 145, Form 146, foreign remittance compliance, TDS on foreign payments, DTAA, NRI taxation, FEMA-related matters and cross-border taxation.

For assistance with your foreign remittance or Form 145/Form 146 compliance, contact our team before initiating the remittance.

Also Read:

• TDS on Sale of Property by NRI in India – Complete 2026
• Form 67 Filing for Foreign Tax Credit: ITAT Confirms DTAA Relief
• US Social Security Taxation for NRIs Returning to India
• Income Tax Department Sends more than 22K Intimations Notice for AY 2023 - 24