Form 15CA, now Form 145: which Part you file before sending money abroad
Four Parts, three questions, and one threshold that is measured on the year rather than the transfer.
It is the declaration you file before sending money out of India. Which Part you file depends on whether the payment is chargeable to tax, whether it exceeds ₹5 lakh in the year, and whether you hold an officer's certificate. From 1 April 2026 it is Form 145, under rule 220 of the Income-tax Rules, 2026.
If you miss it: In practice the bank stops you: most will not process an outward remittance without the acknowledgement. The substantive risk is different — a wrong Part on a chargeable payment means tax was not deducted, and that consequence attaches to the remitter.
Form 15CA, rule 37BB up to 31 Mar 2026 · Form 145, rule 220 from 1 Apr 2026 · checked 10 September 2026
Key takeaways
- Form 15CA became Form 145, and Form 15CB became Form 146, from tax year 2026-27.
- It is filed before the remittance, not after. Banks ask for the acknowledgement before they will process it.
- It is event-based — one filing per qualifying remittance, not an annual return.
- An accountant's certificate is needed only for Part C: chargeable, above ₹5 lakh in the year, and no officer's certificate held.
- The declaration does not decide whether tax was correctly deducted. It is an information filing, and it settles nothing.
The Income-tax Act, 2025 replaced the Income-tax Act, 1961 on 1 April 2026 and renumbered almost everything. It did not renumber your notice. Under the repeal-and-savings provision, an assessment, reassessment, appeal or penalty for a tax year before 1 April 2026 stays under the 1961 Act — even where the notice itself arrives after that date. So the number that governs the letter in your hand is decided by the year the letter is about, not by the date it was posted. Both numbers are given on every page here, with the governing one first.
“The provisions of the repealed Income-tax Act shall continue to apply to any proceeding pending on the date of commencement of this Act and to any proceedings initiated on or after the 1st April, 2026 (including notices, assessment, reassessment, recomputation, rectification, penalty, reference, revision and appeals) in respect of any tax year beginning before the 1st April, 2026.”
- Notice about 2025-26 or earlier
- The Income-tax Act, 1961 numbering is the one that governs it — s. 143(2), s. 156, s. 220, Form 26AS, Form 16. That is most letters arriving in 2026.
- Notice about 2026-27 or later
- The Income-tax Act, 2025 numbering governs — s. 270(8), s. 289, s. 411, Form 168, Form 130. In practice, letters from 2027 onward.
Which Part you file — the decision that matters
The form has four parts and you file one of them. Which one turns on three questions asked in order, and getting the order right is most of the work.
First: is the payment chargeable to tax in India at all? If it is not, the answer is Part D and no accountant is involved. If it is, move on.
Second: does the payment, aggregated with other remittances to that payee in the financial year, exceed ₹5 lakh? If not, Part A, and again no accountant. If it does, move on.
Third: do you hold an order or certificate from the Assessing Officer determining the sum chargeable? If you do, Part B. If you do not, Part C — and Part C is the one that requires a certificate from a Chartered Accountant.
| Part | When | Accountant's certificate? |
|---|---|---|
| Part A | Chargeable to tax, and the aggregate in the financial year does not exceed ₹5 lakh | No |
| Part B | Chargeable, above ₹5 lakh, and you hold an order or certificate from the Assessing Officer | No — the officer's certificate does that work |
| Part C | Chargeable, above ₹5 lakh, and no officer's certificate | Yes — Form 15CB, now Form 146 |
| Part D | Not chargeable to tax in India | No |
The ₹5 lakh test is on the aggregate of remittances to that payee during the financial year, not on the single payment — which is what catches people making several smaller transfers.
Four transfers of ₹1.5 lakh each to the same payee in one year total ₹6 lakh, and the fourth one crosses the threshold. People who have filed Part A three times without an accountant are frequently surprised at the fourth, and the surprise usually arrives at the bank counter with a deadline attached. Track the running total per payee per financial year, not per transfer.
The first question is the hard one
Everything above depends on whether the payment is chargeable to tax in India, and that is a question of law rather than a box to tick. It is also where the real risk sits, because Part D — the no-tax route — is the one with no accountant and no officer looking at it, which makes it the easiest to file and the easiest to get wrong.
A remittance of your own money from an NRO account after tax has been paid is a different thing from a payment for services rendered abroad, which is different again from a royalty, a dividend, or a purchase of goods. Some are plainly outside Indian tax; some are plainly inside it; and a substantial middle ground turns on the treaty, on where services were performed, and on whether there is a business connection in India.
Filing Part D on a payment that was in fact chargeable does not make it non-chargeable. It leaves the remitter having failed to deduct, with the consequences that attach to that — and the bank's acceptance of the form is not a view on the merits.
The declaration is an information provision. It does not itself charge tax, and furnishing it does not settle whether tax was correctly deducted or whether any was due. It gives the department a record of money leaving the country against a stated tax position. If that position was wrong, the form is evidence of what you said rather than protection for having said it.
How it is filed, and when
It is event-based rather than periodic: one filing per qualifying remittance. A standing arrangement of monthly payments means a filing each month, which is administratively tedious and frequently forgotten once the first one has gone through smoothly.
- 1Work out the Part, using the three questions above, and check the running annual total for that payee before deciding.
- 2If Part C applies, get the accountant's certificate first. It is uploaded and then drawn into the declaration, so it has to exist before the declaration can be completed.
- 3File the declaration electronically on the e-filing portal, under the income tax forms section, before the remittance is made.
- 4Take the acknowledgement to the bank. Banks generally will not process an outward remittance without it, and that is the practical enforcement mechanism — not the department, the bank.
- 5Keep the filing with the transaction record. It is the document you will be asked for if the remittance is ever queried.
What changed on 1 April 2026
The forms were renumbered and the framework moved into the new Act, but the mechanism did not change. Form 15CA became Form 145 and Form 15CB became Form 146, both under rule 220 of the Income-tax Rules, 2026, with the framework sitting in the compliance and reporting provisions of the Income-tax Act, 2025.
The four-Part structure, the ₹5 lakh threshold and the circumstances requiring an accountant's certificate are unchanged. What has changed is the numbering, and — as everywhere else on this cluster — which numbering applies depends on when the remittance is made rather than on today's date. The new forms apply to remittances made on or after 1 April 2026.
| What it is | Until 31 March 2026 | From 1 April 2026 |
|---|---|---|
| The remitter's declaration | Form 15CA | Form 145 |
| The accountant's certificate | Form 15CB | Form 146 |
| The rule | Rule 37BB, Income-tax Rules, 1962 | Rule 220, Income-tax Rules, 2026 |
| The certificate that removes the need for an accountant | s. 195(2)/(3) order, or s. 197 certificate | s. 395(1)/(2) |
Who actually has to do this
The obligation sits with the remitter — the person sending the money — not the recipient. That matters because the remitter is frequently an Indian resident sending money to a non-resident, and the tax consequence of getting it wrong lands on them.
- An Indian company paying a foreign supplier, consultant or parent.
- An individual remitting to a relative abroad, or paying foreign university fees, or buying property overseas.
- An NRI repatriating money from an NRO account — where the aggregate limit for repatriation is separately capped at one million US dollars per financial year.
- A buyer paying an NRI seller, where part of the consideration is being sent abroad.
Repatriating from an NRO account. People treat it as moving their own money — which it largely is — and file Part D on that basis. Whether that is right depends on whether the funds in the account represent income already taxed, or income not yet taxed, and the bank is not going to work that out for you. Where the account holds a mix, this is worth an accountant rather than an assumption.
Worked examples
Example 1: Four transfers that became a Part C on the fourth
- Payee
- A foreign consultant
- Transfers
- ₹1,50,000 × 4 across one financial year
- Chargeable
- Yes — fees for technical services
- Filed
- Part A, three times
- 1.The threshold is on the aggregate to that payee in the financial year, not on the individual payment.
- 2.After three transfers the running total is ₹4,50,000, still within Part A.
- 3.The fourth takes it to ₹6,00,000, which exceeds ₹5 lakh — so that remittance needs Part C and an accountant's certificate.
- 4.The certificate has to exist before the declaration can be completed, and the bank will not process the transfer until the acknowledgement exists.
A perfectly ordinary arrangement that becomes an accountant's engagement partway through the year, usually discovered at the counter. Tracking the running total per payee is the whole of the prevention.
Example 2: A Part D filed on a payment that was chargeable
- Payment
- ₹12,00,000 to a foreign company
- For
- Software, licensed rather than sold outright
- Filed
- Part D, as not chargeable
- Tax deducted
- None
- 1.Whether a payment for software is a royalty or a purchase is a genuinely contested question that turns on what was actually licensed and on the treaty.
- 2.Filing Part D records a position; it does not establish one. The bank processed the remittance because the acknowledgement existed, not because anyone agreed with it.
- 3.If the payment was in fact chargeable, the remitter failed to deduct — and the consequences of failing to deduct attach to the remitter, not to the payee who has the money.
- 4.The declaration is then evidence of the position taken, which is useful if the position was reasonable and uncomfortable if it was not.
Part D is the easiest route to file and the most expensive to get wrong, precisely because nobody reviews it. Where chargeability is genuinely arguable, a certificate from the Assessing Officer determining the sum chargeable is worth far more than a confident declaration.
Example 3: An NRO repatriation on mixed funds
- Account
- NRO, holding rent, interest and sale proceeds
- Proposed remittance
- ₹40,00,000
- Assumption made
- Own money, so Part D
- 1.Some of the balance represents income on which tax has already been paid; some represents amounts on which the position is less clear.
- 2.Part D asserts the whole remittance is not chargeable, which is a statement about all of it rather than most of it.
- 3.The separate repatriation cap — one million US dollars per financial year from an NRO account — is a foreign exchange limit and is a different question from the tax one. Satisfying it says nothing about chargeability.
- 4.Where the account holds a mix, the safe route is an accountant's view on the composition before filing, rather than a single assertion about the lot.
The commonest individual failure in this area. Two limits, two regimes, and a bank that checks one of them — the foreign exchange cap — while the tax declaration is taken on trust.
More questions about this page
Is Form 15CA now Form 145?▼
When do I need Form 15CB as well as Form 15CA?▼
Is the ₹5 lakh threshold per payment or per year?▼
Do I need to file if the payment is not taxable in India?▼
When do I file it — before or after sending the money?▼
Who files it — the sender or the recipient?▼
Does filing Form 15CA mean my tax position is accepted?▼
Can I avoid the accountant's certificate?▼
Does this apply to repatriating money from my own NRO account?▼
What if I get the Part wrong?▼
Official sources checked
The statutes, rules and regulator pages the statements on this page were checked against.
- Income-tax Rules, 2026 — rule 220, with Form 145 and Form 146Notified by CBDT Notification No. 22/2026, G.S.R. 198(E), 20 March 2026, applying to remittances made on or after 1 April 2026.
- Income-tax Act, 2025 — the compliance and reporting framework at s. 397(3)(d), with ss. 393, 395 and 462An information provision: it does not itself charge tax, and furnishing the declaration does not settle whether tax was correctly deducted.
- Income-tax Rules, 1962 — rule 37BB, with Forms 15CA and 15CBGoverns remittances made up to 31 March 2026.
You are here
Working out what has to be filed before money leaves India
What to do next
- 1
If you have landed in Part C
That is the accountant's certificate — what it actually certifies, when it can be declined, and what it costs.
Form 15CB, now Form 146 → - 2
If you would rather not need an accountant at all
An officer's certificate determining the sum chargeable moves the remittance into Part B — and carries more weight if it is ever questioned.
Lower TDS certificate → - 3
If the payment is chargeable but a treaty gives a lower rate
Treaty relief runs on its own document trail, and it has to be in place before the payment rather than after.
Form 10F, now Form 41 → - 4
If the remittance is proceeds of an Indian property sale
The withholding on that sale is computed on the whole price rather than the gain, which is a much larger problem than the remittance form.
Lower TDS certificate →
This page is general information about procedure and deadlines, checked against the provisions in force on the date shown. It is not advice on your own assessment, and a notice that looks routine can turn on facts a page cannot see. Where money or a limitation period is at stake, put the notice in front of a practising Chartered Accountant.