Understanding the New Income Tax Form 145 and Form 146

🗓 September 22, 2026 | 📂 Excel Form 145 & 146 JSON Bulk Generator

Understanding the New Income Tax Form 145 and Form 146 (Replacing Form 15CA & 15CB)

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With the introduction of the new Income Tax Act, 2025, the procedures for foreign remittances have undergone a significant structural update. The familiar compliance mechanism for overseas payments has shifted. Most notably, the legacy Form 15CA has been officially replaced by Form 145, and the Chartered Accountant certificate Form 15CB has been replaced by Form 146. This complete guide covers the Income Tax Form 145 and Form 146 details, their statutory requirements, and what businesses need to know to ensure seamless cross-border transactions.

The Transition: Out with the Old, In with the New

Under the previous Income Tax Act, 1961 (specifically Section 195(6)), any person making a payment to a non-resident or a foreign company was required to furnish information using Form 15CA, and where applicable, obtain a CA certificate in Form 15CB.

Effective April 1, 2026, the new Section 397(3)(d) of the Income-tax Act, 2025 dictates these rules. To align with the updated digital compliance framework, the government has renamed and updated these forms:

Old Form 15CA is now Form 145: The primary declaration filed by the remitter before transferring funds abroad.
Old Form 15CB is now Form 146: The mandatory Chartered Accountant’s certificate verifying tax deductions and treaty benefits.

What is the New Form 145? (Detailed Breakdown)

Form 145 is the comprehensive foreign-remittance information form submitted by the person or business making a payment to a non-resident. It provides the Income Tax Department with clear details about the purpose of the remittance, preventing tax leakage and ensuring Double Taxation Avoidance Agreement (DTAA) compliance.

Depending on the taxability and the amount being remitted, Form 145 is divided into four specific parts:

Part A: Applicable if the remittance is taxable in India, but the aggregate payments during the financial year do not exceed ₹5 Lakh. No CA certificate is required.
Part B: Applicable for taxable remittances exceeding ₹5 Lakh during the financial year, provided an Assessing Officer (AO) certificate (such as a lower or nil deduction certificate) has been obtained.
Part C: This is the most common scenario for corporate payments. It applies when the taxable remittance exceeds ₹5 Lakh and no AO certificate is available. To file Part C, a CA certificate in Form 146 is strictly required first.
Part D: Applicable when the remittance is explicitly not chargeable to tax under the Act (e.g., specific import payments). This acts as a reporting declaration without needing CA certification.

What is the New Form 146?

Form 146 serves as the official Chartered Accountant certificate. When a business needs to send more than ₹5 Lakh overseas (and the amount is taxable), they must appoint a CA through the e-Filing portal.

The Chartered Accountant is responsible for examining the transaction and certifying the following details in Form 146:

The exact nature and purpose of the remittance.
The taxability of the payment in India under relevant provisions.
The applicability of DTAA benefits.
The correct withholding tax (TDS) rate, including applicable surcharge and health/education cess.

Once the CA successfully files and e-verifies Form 146 using their Digital Signature Certificate (DSC), an acknowledgement number is generated. The remitter must input this specific acknowledgement number to unlock and file Form 145 Part C.

The New Compliance Workflow

To avoid delays with authorized dealer banks processing your foreign transfers, follow this updated procedural workflow:

Determine Taxability: Evaluate if the foreign payment is taxable in India and calculate the aggregate FY limit (over or under ₹5 Lakh).
Assign a CA: If the payment requires Part C filing, assign your Chartered Accountant on the Income Tax e-filing portal.
File Form 146: The CA reviews the transaction, deducts applicable TDS, and submits Form 146.
Generate Acknowledgement: Obtain the Form 146 acknowledgement receipt number.
File Form 145: The remitter logs in, enters the CA’s acknowledgement number, fills out Form 145 Part C, and submits it.
Submit to Bank: Hand over the generated forms and TDS challan to your bank for processing the remittance.

Filing individual forms online can become tedious, especially when dealing with bulk foreign remittances or correcting session timeouts on the e-filing portal. For CAs and corporate finance teams looking to streamline this new compliance framework, the XLTOOL Form 145 & 146 JSON Bulk Generator provides a 100% offline Excel utility. You can prepare unlimited records securely on your desktop, automatically copy CA details between forms, and generate error-free bulk JSON files ready for instant portal upload. Simplify your transition to the new tax laws and download the XLTOOL utility today.