Erstwhile Form 15CA / 15CB • Section 397(3)(d) • Rule 220 • TCS Budget 2026 Updated
Under the Income Tax Act 2025 (effective 1 April 2026), Form 15CA and 15CB have been replaced by Form 145 and Form 146. Whether you're sending money abroad for education, medical treatment, property purchase, investment, or an NRI repatriating funds from your NRO account — CA Alok Kumar provides expert Form 145/146 filing, TCS advisory (Budget 2026 rates — 2% on education & medical), DTAA benefit optimization, Section 393 TDS compliance, and end-to-end bank liaison.
Under the Income Tax Act 2025 — Expert CA services for every type of foreign remittance from India
Expert filing of Form 145 (Part A/B/C/D) and CA certificate in Form 146 (with UDIN verification). Payment nature verification, TDS compliance under Section 393, DTAA applicability, and tax computation. 1-3 day turnaround.
End-to-end NRI/OCI fund repatriation from NRO to NRE or foreign bank account. Tax verification, Form 145/146, bank liaison, A2 form preparation. Up to USD 1 million per tax year.
Section 394 TCS advisory — education (2%), medical (2%), tour package (2% flat), investment (20%). ₹10 lakh threshold. TCS credit & refund assistance during ITR filing.
TDS deduction on payments to NRIs — rent, property sale (capital gains), professional fees, interest. Correct rate determination under Section 393(2) considering DTAA. TDS return in Form 144 & certificate in Form 131.
Application for lower/nil TDS certificate for NRIs under Section 395(1)/395(2). Reduces TDS on property sale, rent, professional income. Enables Form 145 Part B filing without needing Form 146.
Analysis of Double Taxation Avoidance Agreements with 90+ countries. TRC (Tax Residency Certificate) verification, Form 10F filing, treaty rate application for reduced withholding tax.
Complete handling of property sale by NRIs — capital gains computation, TDS deduction u/s 393(2), Form 145/146 filing, bank coordination for repatriation of sale proceeds.
Coordination with AD (Authorized Dealer) banks — SBI, ICICI, HDFC, Axis, etc. A2 form preparation, purpose code mapping, RBI compliance, document submission for smooth remittance.
Form 145 (erstwhile Form 15CA) has 4 parts, prescribed under Rule 220 of the Income Tax Rules 2026. Which part you file depends on whether the payment is taxable, the amount, and whether you have a CA certificate or AO order.
Taxable remittance — up to ₹5 Lakh in Tax Year
Self-declaration by remitter. No CA certificate (Form 146) required. Filed when the taxable remittance or aggregate does not exceed ₹5 lakh during the tax year.
Taxable > ₹5L + AO Order u/s 395(1)/395(2)
Filed when taxable remittance exceeds ₹5 lakh AND you have obtained a certificate from Assessing Officer under Section 395(1) or 395(2) of the Income Tax Act 2025. This eliminates the need for Form 146 — a key duplication-reduction under the new Act.
Taxable > ₹5L + CA Certificate (Form 146)
The most common part. Filed when taxable remittance exceeds ₹5 lakh, no AO certificate obtained, and a Chartered Accountant has issued Form 146 with valid UDIN. CA verifies TDS, DTAA, and compliance under Section 393.
Remittance NOT chargeable to tax
Simple self-declaration when the remittance is not chargeable to tax under the Income Tax Act 2025. No CA certificate required. Most individual LRS transfers for personal purposes fall here.
Budget 2026 updated rates — Section 394, Income Tax Act 2025
Section 394, Income Tax Act 2025 | Threshold ₹10 Lakh per Tax Year (unchanged)
| Purpose of Remittance | TCS Rate (Budget 2026) | Old Rate (Before Apr 2026) | Threshold | Key Note |
|---|---|---|---|---|
| Education (Self-Funded) | 2% | 5% | Above ₹10 Lakh | Reduced from 5% to 2% |
| Education (Loan u/s 80E) | 0% | 0% | — | No TCS if funded via education loan |
| Medical Treatment Abroad | 2% | 5% | Above ₹10 Lakh | Reduced from 5% to 2% |
| Overseas Tour Package | 2% flat | 5% / 20% | No threshold — from ₹1 | Flat 2% on entire amount — major simplification |
| Other Purposes (Investment, Gift, etc.) | 20% | 20% | Above ₹10 Lakh | No change — remains 20% |
Important: TCS is NOT an additional tax — it is an advance tax collected by the bank/authorized dealer. It reflects in your Form 26AS and is fully adjustable against your income tax liability when filing ITR. If no tax is payable, you can claim a full refund of TCS. The ₹10 lakh threshold is a combined limit across all LRS categories and all authorized dealers.
Under Income Tax Act 2025 — NRIs can repatriate up to USD 1 million per tax year from their NRO account
CA verifies that all Indian income (rent, interest, capital gains, dividends) has been properly offered to tax and ITR filed. Checks Form 26AS, AIS, TDS credits, and outstanding demands.
Chartered Accountant prepares and files Form 146 online on incometax.gov.in with mandatory UDIN (Unique Document Identification Number). Certifies payment nature, applicable TDS rate under Sec 393, DTAA provisions, and amount eligible for remittance.
After Form 146 is filed by CA, the NRI/remitter files Form 145 (Part C) on the income tax portal under "Forms as per Income Tax Act 2025." Links the Form 146 acknowledgement number. E-verifies via DSC or EVC.
Submit Form 145 acknowledgement + Form 146 certificate + A2 form + supporting documents to your bank (AD — Authorized Dealer). Bank processes remittance within 1-3 working days.
Rule 220(3) of Income Tax Rules 2026 (erstwhile Rule 37BB) lists 33 exempt payment categories — 5 more than the old rules, adding import-related RBI purpose codes
| # | Nature of Payment (Rule 220 Exempt) | Key Condition |
|---|---|---|
| 1 | Remittance by individual under LRS not requiring RBI approval | Individual — within LRS USD 250,000 |
| 2 | Import of goods (trade payments) | With valid import documentation |
| 3 | Shipping / airline ticket purchase | Direct payment to carrier |
| 4 | Remittance for medical treatment | Individual — doesn't need RBI approval |
| 5 | Remittance for education fees | Individual — university fee payment |
| 6 | Living expenses of student abroad | Individual — within LRS limit |
| 7 | Travel abroad (business or personal) | Individual — doesn't need RBI approval |
| 8 | Gift/donation to foreign person | Individual — within LRS limit |
| 9 | Maintenance of close relatives abroad | Individual — within LRS limit |
| 10 | Indian investment abroad (equity/debt) | Individual under LRS |
| 11 | Units in IFSC (International Financial Services Centre) | File quarterly Form 148 instead |
Note: Rule 220 lists 33 categories of payments exempt from Form 145/146 — expanded from 28 under the old Rule 37BB, adding 5 import-related RBI purpose codes. However, banks may still request these forms under their internal controls. Payments credited to NRO account (not remitted abroad) also don't require Form 145. When in doubt, consult CA Alok Kumar for clarity.
Triple qualification — technically accurate CA certification in Form 146 with UDIN, legally sound DTAA analysis, and AI-powered compliance verification for every remittance under the new Income Tax Act 2025.
Fast-track Form 145/146 filing. We verify documents, prepare certificate, and file within 1-3 working days. Urgent same-day service available for time-sensitive remittances.
Serving NRIs in USA, UK, Canada, Australia, UAE, Singapore, Europe, and 50+ countries. Complete remote service — no need to visit India physically.
Direct coordination with SBI, ICICI, HDFC, Axis, Kotak, and all AD banks. We handle A2 forms, purpose codes, document submission, and query resolution.
Extensive experience in NRO repatriation, property sale remittance, inheritance transfer, business payments, and all categories of foreign remittance — now seamlessly transitioned to Form 145/146.
Expert knowledge of DTAAs with USA, UK, UAE, Singapore, Australia, Canada, Germany, and 90+ countries. Optimize withholding rates and treaty benefits under the new Act.
Form 145 (erstwhile Form 15CA) is a mandatory declaration filed online on incometax.gov.in before remitting funds outside India. It ensures TDS compliance on payments to non-residents under Section 393. Form 146 (erstwhile Form 15CB) is a certificate issued by a Chartered Accountant with mandatory UDIN, certifying the nature of payment, applicable TDS rate, DTAA provisions, and tax compliance. These are prescribed under Section 397(3)(d) read with Rule 220 of the Income Tax Rules 2026, effective from 1 April 2026.
Under Budget 2026 (Section 394, Income Tax Act 2025), TCS threshold remains ₹10 lakh per tax year. Rates from 1 April 2026: Education (self-funded) 2% (down from 5%), Education (loan u/s 80E) 0%, Medical 2% (down from 5%), Overseas tour packages 2% flat with no threshold (down from 5%/20%), Other purposes 20% (unchanged). TCS is NOT an additional tax — it is fully adjustable against your income tax liability when filing ITR.
The Income Tax Act 2025 (effective 1 April 2026) replaces the 1961 Act entirely. Form 15CA is now Form 145, and Form 15CB is now Form 146. The substantive requirements remain the same — same 4-part structure, same thresholds (₹5 lakh for CA certificate), same compliance logic. The changes are in numbering: Section 195 → 393, Section 197 → 395, Rule 37BB → Rule 220. Key improvement: Form 146 now mandates UDIN for verification, and Rule 220 expanded exempt categories from 28 to 33.
Yes — Forms 15CA/15CB already submitted for remittances made on or before 31 March 2026 remain valid even after the new Act comes into force, provided the remittance is actually completed within the validity period mentioned in the forms. For remittances made on or after 1 April 2026, Form 145 and 146 under the Income Tax Rules 2026 must be used.
Form 146 is required when: (a) remittance is chargeable to tax under the Income Tax Act 2025, (b) aggregate remittance exceeds ₹5 lakh in the tax year, and (c) no certificate from AO under Section 395(1)/395(2) has been obtained. Form 146 is NOT required for Part A (≤ ₹5L), Part B (AO certificate obtained), or Part D (not taxable). A key improvement — where Part B is filed with an AO certificate, Part C is not required, eliminating duplication.
NRIs can repatriate up to USD 1 million per tax year from NRO to NRE or foreign bank account. Process: (1) Ensure all Indian income is taxed and ITR filed, (2) Get CA certificate in Form 146 (with UDIN), (3) File Form 145 online, (4) Submit acknowledgement + A2 form + documents to bank, (5) Bank processes within 1-3 days. No physical presence in India required — the entire process can be done remotely with CA Alok Kumar's assistance. TCS under LRS does not apply to NRIs as LRS is only for resident individuals.
Non-filing or furnishing inaccurate information in Form 145 can attract a penalty of up to ₹1,00,000. Banks will refuse to process the remittance without a valid Form 145 acknowledgement. Filed Form 145 can be withdrawn within 7 days if needed. There is no time limit for filing Form 145, but it must be filed before the remittance is made.
Form 146 mandates quoting of UDIN (Unique Document Identification Number) issued by ICAI (Institute of Chartered Accountants of India). Only Form 146 submissions with a valid UDIN are accepted by the income tax portal. This strengthens the credibility and verifiability of the CA certificate. UDIN enables digital verification, prevents fraudulent certificates, and creates an audit trail. CA Alok Kumar files all Form 146 certificates with valid UDIN as standard practice.
For Form 146, provide: PAN of remitter and remittee (if available; else TIN of remittee's country), passport copy (for NRIs), last 2-3 years ITR copies, Form 26AS / AIS, NRO & NRE bank statements, property sale agreement (if applicable), TDS challans, TRC (Tax Residency Certificate) for DTAA benefit, Form 10F (for non-residents claiming DTAA), and invoice/contract for the payment. CA Alok Kumar's team provides a detailed checklist upon engagement.
From Form 145/146 filing to NRO repatriation, TCS advisory (Budget 2026 rates), DTAA benefits, Section 393 TDS, and bank liaison — CA Alok Kumar handles your entire foreign remittance compliance under the Income Tax Act 2025. NRIs served worldwide — no physical visit needed.
