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 filed before sending money out of India — but rule 220(3) takes a great many remittances out of it entirely, including ordinary Liberalised Remittance Scheme transfers by an individual. Where it is required, the Part turns on chargeability, on whether payments in the tax year exceed ₹5 lakh, and on whether a certificate from the Assessing Officer exists. 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: an authorised dealer will not process an outward remittance without the printed form and the acknowledgement. Two consequences sit behind that. Not furnishing the information, or furnishing it inaccurately, carries a penalty of up to ₹1,00,000 under s. 462. And a wrong Part on a chargeable payment means tax was not deducted — a consequence that attaches to the remitter, not the payee.
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.
- Rule 220(3) takes a long list of remittances out of the form altogether — most individual transfers under the Liberalised Remittance Scheme among them. Check the exemption before you work out the Part.
- It is filed before the remittance, not after. The acknowledgement goes to the bank, which will not process the transfer without it.
- An accountant's certificate is needed only for Part C: chargeable, above ₹5 lakh in the tax year, and no certificate from the Assessing Officer held.
- A submitted Form 145 cannot be edited. It can be withdrawn within 7 days of submission, and that is the whole of the correction mechanism.
- Not furnishing it, or furnishing inaccurate information in it, carries a penalty of up to ₹1,00,000 under s. 462 — separately from anything owed on the tax itself.
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.
First: check whether you need to file at all
Almost every page on this subject opens with the four Parts. That is the second question. The first is whether rule 220 asks anything of you at all, because sub-rule (3) takes a long list of remittances out of the requirement entirely — and that list covers a great deal of what individuals actually send abroad.
Three exemptions, and the first is the one that matters to most individuals. No information is required where the remittance is made by an individual and does not require prior approval of the Reserve Bank of India under the foreign exchange rules — which is the ordinary Liberalised Remittance Scheme position. It is also not required for a remittance by a Unit in an International Financial Services Centre. And it is not required where the payment is of a nature specified in the rule’s list of Reserve Bank purpose codes.
That third exemption is a schedule of purpose codes rather than a description, and it is long: Indian investment abroad, loans extended to non-residents, imports, transport and freight, travel, education, insurance, diplomatic and consular expenses, donations, refunds of tax, and more. The purpose code is the one your bank puts on the outward remittance form. If the code the bank is using appears in the rule, there is nothing for you to file.
| The exemption | What it covers in practice |
|---|---|
| A remittance by an individual that does not require prior RBI approval | The ordinary Liberalised Remittance Scheme route — the way most individual transfers abroad are made. This is why the everyday individual cases are usually outside the form rather than inside it. |
| A remittance by a Unit in an International Financial Services Centre | IFSC Units, as defined for foreign exchange and special economic zone purposes. |
| A payment of a nature specified in the rule’s list of RBI purpose codes | A long schedule — Indian investment abroad, loans to non-residents, imports, freight and transport, travel, education, insurance, diplomatic expenses, donations, refunds of tax and others. Check it against the purpose code on your bank’s outward remittance form. |
These are exemptions from furnishing the information, not from tax. A payment can sit outside rule 220 entirely and still be chargeable, with a withholding obligation on the remitter. The two questions are separate, and the second one does not go away because the first was answered.
An earlier version listed foreign university fees, family support and buying property overseas as remittances that automatically require the form. That was wrong. All three are ordinarily made by an individual under the Liberalised Remittance Scheme without prior RBI approval, and education and travel additionally sit inside the purpose-code schedule — so in the ordinary case none of them requires Form 145 at all. Check the exemption first, against the purpose code the bank is actually using.
Which Part you file — the decision that matters
If rule 220(3) does not exempt the remittance, 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, or the aggregate of such payments made during the tax year, exceed ₹5 lakh? If not, Part A, and again no accountant. If it does, move on.
Third: do you hold a certificate from the Assessing Officer under s. 395(1) or s. 395(2)? 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 in Form 146.
| Part | When | Accountant's certificate? |
|---|---|---|
| Part A | Chargeable to tax, and the payment or the aggregate of such payments in the tax year does not exceed ₹5 lakh | No |
| Part B | Chargeable, above ₹5 lakh, and a certificate under s. 395(1) or s. 395(2) has been obtained from the Assessing Officer | No — the officer’s certificate does that work |
| Part C | Chargeable, above ₹5 lakh, and no such certificate | Yes — Form 15CB, now Form 146 |
| Part D | Not chargeable to tax in India, and not a payment that rule 220(3) exempts | No |
Rule 220(1)(a) sets the test as the amount of payment, or the aggregate of such payments, made during the tax year. It is a running total across the year rather than a per-transfer test — which is what catches people making several smaller transfers.
Four transfers of ₹1.5 lakh across one tax year total ₹6 lakh, and the fourth crosses the threshold. People who have filed Part A three times are frequently surprised at the fourth, and the surprise usually arrives at the bank counter with a deadline attached. What the rule does not contain is a separate ₹5 lakh allowance for each payee: it speaks of the payment, or the aggregate of such payments, made during the tax year, and stops there. Several sources state a per-payee threshold; none of them can point at the words. Until the department says otherwise, keep the running total of chargeable remittances for the year and treat the threshold as reached when that total does — it is the reading the rule supports, and it is the safe one.
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, non-exempt 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.
One thing to know before you submit rather than after. A submitted Form 145 cannot be edited. If a figure is wrong, the only route is to withdraw it — and withdrawal is available for 7 days from the date of submission, after which the filing stands as made and the correction has to be dealt with as a substantive matter rather than a clerical one.
- 1Check rule 220(3) first. If the remittance is exempt, nothing below applies.
- 2Work out the Part, using the three questions above, and check the running total of chargeable remittances for the tax year before deciding.
- 3If Part C applies, the accountant files Form 146 first. It is then drawn into your declaration, so it has to exist before the declaration can be completed.
- 4Log in to the e-filing portal and go to e-File, then Income Tax Forms, then File Income Tax Forms. Form 145 sits under the tab for forms as per the Income-tax Act, 2025. Select the tax year and the Part, and complete each panel.
- 5Or use the offline utility: download it, prepare and validate the form on your own machine, generate the file, upload it to the portal and verify it there. The offline route is what makes a large number of remittances manageable.
- 6E-verify and submit. A Digital Signature Certificate is required where the filer is acting under a TAN; otherwise an Electronic Verification Code is accepted.
- 7Print the form and the acknowledgement and give both to the bank — the authorised dealer — before the remittance is processed. That is the practical enforcement mechanism: not the department, the bank.
- 8Keep the filing with the transaction record. It is the document you will be asked for if the remittance is ever queried.
| The position | |
|---|---|
| Where it is filed | The e-filing portal: e-File → Income Tax Forms → File Income Tax Forms, under the tab for forms as per the Income-tax Act, 2025. Online, or through the downloadable offline utility. |
| How it is verified | E-Verify and submit — Digital Signature Certificate where the filer is acting under a TAN, otherwise an Electronic Verification Code. |
| If the payee has no PAN | Give the payee’s Tax Identification Number in their country of residence instead, together with the residency documentation relied on for any treaty rate. |
| Correcting it | It cannot be edited. It can be withdrawn within 7 days of submission, and not afterwards. |
| What goes to the bank | A printed copy of the form and the acknowledgement, before the authorised dealer processes the remittance. |
| Penalty for not filing, or for inaccurate information | Up to ₹1,00,000 under s. 462 of the Income-tax Act, 2025 — the successor to s. 271I of the 1961 Act, and separate from anything owed on the tax itself. |
There is no revised Form 145. A wrong amount, a wrong Part or a wrong payee is fixed by withdrawing the filing within 7 days of submitting it and filing again. After that the declaration stands as made, and a wrong one is evidence of the position you took. Check the figures against the invoice before you submit rather than after the bank has the acknowledgement.
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) or s. 395(2) certificate |
| Where no information is required at all | Rule 37BB(3) — individual remittances not needing RBI approval, and the specified purpose codes | Rule 220(3) — the same two, plus remittances by an IFSC Unit |
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.
But it sits there only where rule 220(3) has not taken the remittance out of the requirement, and for individuals it very often has. The useful way to read the list below is as two groups: the entity payments, which are usually inside the form, and the individual transfers, which usually are not.
- An Indian company paying a foreign supplier, consultant or parent. Ordinarily inside the requirement, and the commonest Part C.
- A firm or company paying a royalty, a licence fee or fees for technical services abroad. Inside, and the chargeability question is the hard one.
- An individual paying foreign university fees, supporting family abroad, or buying property overseas. Ordinarily made under the Liberalised Remittance Scheme without prior RBI approval, so ordinarily exempt under rule 220(3)(a) — and education and travel additionally appear in the purpose-code schedule. Check the purpose code rather than assuming either way.
- An NRI repatriating money from an NRO account. Whether the exemption applies depends on whether that particular repatriation needs prior RBI approval; the separate one million US dollar annual cap is a foreign exchange limit and answers a different question.
- A buyer paying an NRI seller, where part of the consideration is being sent abroad. The remittance form is the smaller of the two problems here — the withholding on the sale price is the larger one.
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
- Remitter
- An Indian company
- Payee
- A foreign consultant
- Transfers
- ₹1,50,000 × 4 across one tax year
- Chargeable
- Yes — fees for technical services
- Exempt under rule 220(3)?
- No — not an individual remitter, and not a listed purpose code
- Filed
- Part A, three times
- 1.Rule 220(3) is checked first and does not help: the remitter is a company, so the individual exemption is unavailable, and fees for technical services are not in the purpose-code schedule.
- 2.The threshold is the payment, or the aggregate of such payments, made during the tax year. It is a running total, not a per-transfer test.
- 3.After three transfers the running total is ₹4,50,000, still within Part A.
- 4.The fourth takes it to ₹6,00,000, which exceeds ₹5 lakh — so that remittance needs Part C and Form 146 from a Chartered Accountant.
- 5.Form 146 has to exist before the declaration can be completed, and the bank will not process the transfer until it has the acknowledgement.
A perfectly ordinary arrangement that becomes an accountant’s engagement partway through the year, usually discovered at the counter. Keeping the running annual total is the whole of the prevention. Note what the rule does not give you: a fresh ₹5 lakh for each new payee. Do not plan around one.
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.Ask the rule 220(3) question first: does this particular repatriation require prior RBI approval? Where it does not, no information is required at all and the Part question never arises. Where it does, the form is in play.
- 2.Some of the balance represents income on which tax has already been paid; some represents amounts on which the position is less clear.
- 3.Part D asserts the whole remittance is not chargeable, which is a statement about all of it rather than most of it.
- 4.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 both of the above. Satisfying it says nothing about chargeability, and nothing about rule 220.
- 5.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 Form 145 for money sent under the LRS?▼
Can Form 145 be corrected or withdrawn after filing?▼
What is the penalty for not filing Form 15CA or Form 145?▼
What if the overseas payee has no PAN?▼
Do I need to file if the payment is not taxable in India?▼
When do I file it — before or after sending the money?▼
Does Form 145 need a digital signature?▼
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 Forms 145, 146, 147 and 148Notified by CBDT Notification No. 22/2026, G.S.R. 198(E), 20 March 2026, applying to remittances made on or after 1 April 2026. Rule 220(1) carries the ₹5 lakh test as the amount of payment, or the aggregate of such payments, made during the tax year — with no separate per-payee allowance. Rule 220(3) carries the three exemptions and the schedule of RBI purpose codes.
- The portal path, the online and offline filing modes, the e-Verify and submit step with DSC required for TAN filers, the 7-day withdrawal window, the TIN alternative where the payee has no PAN, and the requirement to give the printed form and acknowledgement to the authorised dealer. The statutory site refuses automated requests from this environment; the portal does not, and the FAQ document was read through a reproduction — see research/income-tax-gap.md §0.
- 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. s. 462 carries the penalty of up to ₹1,00,000 for not furnishing it or furnishing inaccurate information, replacing s. 271I of the 1961 Act. s. 395(1) is the payee’s certificate and s. 395(2) the payer’s determination, either of which puts a remittance into Part B.
- 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.