{"id":1417,"date":"2026-05-26T10:37:48","date_gmt":"2026-05-26T06:07:48","guid":{"rendered":"https:\/\/caalokkumar.com\/my-writing\/?p=1417"},"modified":"2026-05-26T10:37:49","modified_gmt":"2026-05-26T06:07:49","slug":"income-tax-act-2025-new-forms-compliance-statements","status":"publish","type":"post","link":"https:\/\/caalokkumar.com\/my-writing\/income-tax-act-2025-new-forms-compliance-statements\/","title":{"rendered":"Income-tax Act, 2025: New Forms & Compliance Statements from 1 April 2026"},"content":{"rendered":"\n

Income-tax Act, 2025: New Forms & Compliance Statements from 1 April 2026<\/h2>\n\n\n\n

PAN, TAN, Form 121, Form 145\/146, Form 26, Form 104 and Other Key Compliance Changes Explained<\/h3>\n\n\n\n

The Income-tax Act, 2025 has introduced a new structure for India\u2019s direct tax law from 1 April 2026<\/strong>. While the basic tax policy has largely been retained, many statutory forms and compliance statements have been renumbered, simplified, merged or restructured under the Income-tax Rules, 2026.<\/p>\n\n\n\n

For taxpayers, businesses, NRIs, employers, deductors, banks, charitable trusts and professionals, the practical question is:<\/p>\n\n\n\n

Which form should be used after 1 April 2026 \u2014 the old form or the new form?<\/strong><\/p>\n\n\n\n

This article explains the key changes in PAN application, TAN application, Form 60\/61, lower TDS certificate, Form 15G\/15H, salary arrears relief, foreign remittance forms, tax audit report and charitable trust registration<\/strong> under the Income-tax Act, 2025.<\/p>\n\n\n\n

For return filing support, you may also refer to our dedicated page on ITR Filing Services for AY 2026-27<\/a>.<\/p>\n\n\n\n

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1. Basic Transition Rule: Old Year, Old Form \u2014 New Year, New Form<\/h2>\n\n\n\n

The most important principle is simple:<\/p>\n\n\n\n

Transaction \/ Compliance<\/th>Applicable Law<\/th>Form to be Used<\/th><\/tr><\/thead>
Compliance relating to FY 2025-26 or earlier<\/td>Income-tax Act, 1961<\/td>Old forms<\/td><\/tr>
Compliance relating to Tax Year 2026-27 onwards<\/td>Income-tax Act, 2025<\/td>New forms<\/td><\/tr>
Applications pending as on 31 March 2026<\/td>Old Act continues, unless specifically provided otherwise<\/td>Fresh filing not required merely due to transition<\/td><\/tr>
Fresh applications on or after 1 April 2026<\/td>Income-tax Act, 2025<\/td>New prescribed forms<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n

This is important because many filings may be made after 1 April 2026, but they may still relate to FY 2025-26. In such cases, the relevant year of transaction or compliance must be checked carefully.<\/p>\n\n\n\n

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2. PAN Application: Form 49A \/ 49AA Replaced by New Category-Specific Forms<\/h2>\n\n\n\n

Under the old system, Form 49A<\/strong> was used by Indian applicants and Form 49AA<\/strong> was used by foreign applicants for PAN application.<\/p>\n\n\n\n

Under the Income-tax Act, 2025 framework, these have been split into separate forms:<\/p>\n\n\n\n

Applicant Category<\/th>Old Form<\/th>New Form<\/th><\/tr><\/thead>
Indian individual<\/td>Form 49A<\/td>Form 93<\/td><\/tr>
Indian company \/ entity<\/td>Form 49A<\/td>Form 94<\/td><\/tr>
Foreign individual<\/td>Form 49AA<\/td>Form 95<\/td><\/tr>
Foreign entity<\/td>Form 49AA<\/td>Form 96<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n

This restructuring makes the forms more specific and easier to fill, because each form will contain only the fields relevant to that applicant category.<\/p>\n\n\n\n

Practical point:<\/strong> Existing PAN numbers will continue. The new forms are relevant for fresh PAN applications filed on or after 1 April 2026.<\/p>\n\n\n\n

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3. TAN Application: Form 49B Split into Form 134 and Form 135<\/h2>\n\n\n\n

The old Form 49B<\/strong> for TAN application has also been split into two new forms:<\/p>\n\n\n\n

Applicant Category<\/th>Old Form<\/th>New Form<\/th><\/tr><\/thead>
Government entities<\/td>Form 49B<\/td>Form 134<\/td><\/tr>
Other than Government entities<\/td>Form 49B<\/td>Form 135<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n

This is relevant for companies, firms, LLPs, employers, government bodies, statutory authorities and other deductors required to deduct or collect tax at source.<\/p>\n\n\n\n

For businesses requiring support in payroll, accounting, TDS and compliance systems, refer to our Virtual CFO and Accounting Outsourcing Services<\/a>.<\/p>\n\n\n\n

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4. Form 60 Becomes Form 97 \u2014 Declaration Where PAN is Not Available<\/h2>\n\n\n\n

Under the Income-tax Act, 1961, where PAN was required but the person did not have PAN, Form 60<\/strong> was used.<\/p>\n\n\n\n

Under the Income-tax Act, 2025:<\/p>\n\n\n\n

Purpose<\/th>Old Form<\/th>New Form<\/th><\/tr><\/thead>
Declaration where PAN is not available<\/td>Form 60<\/td>Form 97<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n

A person who does not have PAN may submit Form 97<\/strong> for specified transactions covered under the new rules.<\/p>\n\n\n\n

This is important for banks, financial institutions, registrars, property transaction handlers and other reporting entities dealing with specified high-value transactions.<\/p>\n\n\n\n

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5. Form 61 Becomes Form 98 \u2014 Half-Yearly Statement of Declarations<\/h2>\n\n\n\n

Earlier, persons receiving Form 60 declarations were required to submit a half-yearly statement in Form 61<\/strong>.<\/p>\n\n\n\n

Under the new framework:<\/p>\n\n\n\n

Purpose<\/th>Old Form<\/th>New Form<\/th><\/tr><\/thead>
Half-yearly statement of declarations received<\/td>Form 61<\/td>Form 98<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n

The due dates are:<\/p>\n\n\n\n

Declaration Period<\/th>Due Date for Form 98<\/th><\/tr><\/thead>
April to September<\/td>31 October of the financial year<\/td><\/tr>
October to March<\/td>30 April of the next financial year<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n

Reporting entities should update their internal compliance checklist so that Form 98 is filed correctly under the new framework.<\/p>\n\n\n\n

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6. Lower \/ Nil TDS Certificate: Form 13 Becomes Form 128<\/h2>\n\n\n\n

A lower or nil TDS certificate allows a taxpayer to receive income after deduction of tax at a lower rate or at nil rate, where the taxpayer\u2019s estimated total income justifies such relief.<\/p>\n\n\n\n

Purpose<\/th>Old Provision \/ Form<\/th>New Provision \/ Form<\/th><\/tr><\/thead>
Lower \/ nil TDS certificate<\/td>Section 197 \/ Form 13<\/td>Section 395(1) \/ Form 128<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n

A certificate issued under Section 197 of the Income-tax Act, 1961 may remain valid for payments or credits made on or after 1 April 2026, if it was issued for lower or nil deduction in respect of projected receivables for Tax Year 2026-27.<\/p>\n\n\n\n

This is particularly important for NRIs, property sellers, contractors, professionals, consultants and taxpayers expecting excess TDS.<\/p>\n\n\n\n

For NRI property sale, NRO repatriation and lower TDS certificate support, refer to our NRI Tax Consultant in Dwarka, Delhi<\/a> page.<\/p>\n\n\n\n

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7. Form 15G and Form 15H Merged into New Form 121<\/h2>\n\n\n\n

Under the Income-tax Act, 1961:<\/p>\n\n\n\n

Old Form<\/th>Used By<\/th><\/tr><\/thead>
Form 15G<\/td>Resident individual below 60 years \/ eligible persons, subject to conditions<\/td><\/tr>
Form 15H<\/td>Resident senior citizens aged 60 years or more<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n

Under the Income-tax Act, 2025, both forms are merged into one form:<\/p>\n\n\n\n

Purpose<\/th>Old Forms<\/th>New Form<\/th><\/tr><\/thead>
Self-declaration for no TDS<\/td>Form 15G \/ Form 15H<\/td>Form 121<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n

This is a useful simplification because taxpayers often get confused between Form 15G and Form 15H. The new Form 121<\/strong> creates a unified declaration format.<\/p>\n\n\n\n

Another important improvement is the single UIN system<\/strong>. Earlier, each payer or deductor generated a separate Unique Identification Number for each Form 15G \/ 15H. Under the revised framework, a single UIN will be allotted by the Department for each PAN for a given tax year, and declarations submitted to multiple payers will be linked to that UIN.<\/p>\n\n\n\n

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8. Salary Arrears Relief: Form 10E Becomes Form 39<\/h2>\n\n\n\n

Taxpayers receiving salary arrears, advance salary, gratuity, pension commutation, retrenchment compensation or similar receipts may be eligible for tax relief to reduce the impact of bunching of income.<\/p>\n\n\n\n

Purpose<\/th>Old Form<\/th>New Form<\/th><\/tr><\/thead>
Relief for salary arrears \/ advance salary etc.<\/td>Form 10E<\/td>Form 39<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n

Under the Income-tax Act, 2025, this relief is linked with Section 157<\/strong>, and the assessee will be required to file Form 39<\/strong>on or before the due date of return filing under Section 263(1)(c).<\/p>\n\n\n\n

Important transition rule:<\/strong>\u00a0For AY 2026-27, which relates to FY 2025-26, Form 10E will continue to be used. Form 39 applies from Tax Year 2026-27 onwards. Use below calculator to calculate Income Tax Relief.<\/p>\n\n\n\n

Income Tax Relief Calculator \u2014\u00a0Section 89 & Form 10E<\/em> <\/a><\/strong><\/p>\n\n\n\n

For return filing with salary arrears, Form 10E \/ Form 39 support and AIS reconciliation, refer to our Income Tax Return Filing Services<\/a>.<\/p>\n\n\n\n

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9. Foreign Remittance: Form 15CA \/ 15CB Replaced by Form 145 \/ 146<\/h2>\n\n\n\n

This is one of the most important changes for NRIs, foreign companies, businesses and persons making payments to non-residents.<\/p>\n\n\n\n

Purpose<\/th>Old Form<\/th>New Form<\/th><\/tr><\/thead>
Declaration by remitter for foreign remittance<\/td>Form 15CA<\/td>Form 145<\/td><\/tr>
CA certificate for foreign remittance<\/td>Form 15CB<\/td>Form 146<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n

Under the old Act, these forms were linked with Section 195(6). Under the Income-tax Act, 2025, the corresponding requirement is under Section 397(3)(d)<\/strong>.<\/p>\n\n\n\n

The official e-filing portal describes Form 145 as the form for furnishing information for payments to a non-resident or foreign company before remittance, and also confirms that in some cases a CA certificate in Form 146 is required. (Income Tax India<\/a>) Form 146 is the accountant\u2019s certificate for taxable payments to a non-resident or foreign company where the payment or aggregate payments exceed \u20b95 lakh in the tax year. (Income Tax India<\/a>)<\/p>\n\n\n\n

For professional support, refer to our CA Certificate for Foreign Remittance<\/a> page and our local service page on Form 145 and Form 146 Filing in Delhi<\/a>.<\/p>\n\n\n\n

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10. Structure of Form 145: Four-Part Reporting Framework<\/h2>\n\n\n\n

Form 145 has four parts:<\/p>\n\n\n\n

Part<\/th>When Applicable<\/th><\/tr><\/thead>
Part A<\/td>Remittance is taxable and aggregate amount does not exceed \u20b95 lakh during the tax year<\/td><\/tr>
Part B<\/td>Remittance is taxable, exceeds \u20b95 lakh, and AO certificate under Section 395(1) \/ 395(2) has been obtained<\/td><\/tr>
Part C<\/td>Remittance is taxable, exceeds \u20b95 lakh, and CA certificate in Form 146 has been obtained<\/td><\/tr>
Part D<\/td>Remittance is not taxable under the Act, except specified excluded payments<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n

A useful relief in the new framework is that where Part B<\/strong> is filed on the basis of an AO certificate, Form 146 is not required<\/strong>. This reduces duplication, professional cost and compliance burden for remitters.<\/p>\n\n\n\n

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11. UDIN Verification in Form 146<\/h2>\n\n\n\n

Form 146 introduces UDIN-based verification through ICAI systems. This is intended to ensure that only genuine CA certificates are accepted and to reduce the risk of fake certificates in foreign remittance transactions.<\/p>\n\n\n\n

For NRIs and businesses, this means better reliability, stronger documentation and smoother bank-level processing.<\/p>\n\n\n\n

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12. Remittance in April 2026 for Liability Accrued Before 31 March 2026<\/h2>\n\n\n\n

A practical issue may arise where liability accrued in FY 2025-26, but the foreign remittance is actually made in April 2026.<\/p>\n\n\n\n

The broad approach is:<\/p>\n\n\n\n

Issue<\/th>Applicable Law<\/th><\/tr><\/thead>
Taxability of underlying income<\/td>Law applicable to year of accrual, i.e., Income-tax Act, 1961 if income accrued before 31 March 2026<\/td><\/tr>
Procedural reporting form<\/td>Law in force on date of remittance, i.e., Form 145 \/ 146 if remittance is made on or after 1 April 2026<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n

This distinction is important in NRI remittance, royalty, fees for technical services, dividend, interest and other cross-border payment cases.<\/p>\n\n\n\n

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13. Tax Audit: Form 3CA \/ 3CB \/ 3CD Merged into Form 26<\/h2>\n\n\n\n

Under the Income-tax Act, 1961, tax audit reports were filed in:<\/p>\n\n\n\n

Old Form<\/th>Purpose<\/th><\/tr><\/thead>
Form 3CA<\/td>Audit report where accounts are audited under another law<\/td><\/tr>
Form 3CB<\/td>Audit report in other cases<\/td><\/tr>
Form 3CD<\/td>Statement of particulars<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n

Under the Income-tax Act, 2025, these forms have been merged into one unified form:<\/p>\n\n\n\n

Purpose<\/th>Old Forms<\/th>New Form<\/th><\/tr><\/thead>
Tax audit report<\/td>Form 3CA \/ 3CB \/ 3CD<\/td>Form 26<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n

For FY 2025-26 \/ AY 2026-27, the tax audit report will still be filed in Form 3CA \/ 3CB \/ 3CD. For Tax Year 2026-27, the tax audit report will be filed in Form 26.<\/p>\n\n\n\n

For tax audit filing and review, refer to our dedicated page on Tax Audit under Section 44AB<\/a> and our broader Audit and Assurance Services<\/a>.<\/p>\n\n\n\n

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14. Key Features of New Form 26 for Tax Audit<\/h2>\n\n\n\n

The new Form 26 is not merely a change in numbering. It is a structural consolidation of tax audit reporting.<\/p>\n\n\n\n

Key features include:<\/p>\n\n\n\n

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  1. Form 3CA, Form 3CB and Form 3CD are consolidated into one form.<\/li>\n\n\n\n
  2. Audit clauses are aligned with the ITR framework to reduce mismatch between audit report and return of income.<\/li>\n\n\n\n
  3. Reporting of disallowable expenditure is streamlined.<\/li>\n\n\n\n
  4. Separate schedules have been inserted for losses, depreciation, deductions, prior period items, receipts, income and expenses.<\/li>\n\n\n\n
  5. Auditor\u2019s membership number, firm registration number and UDIN disclosure are mandatory.<\/li>\n\n\n\n
  6. Dedicated reporting fields exist for capital receipts and deemed incomes not routed through the Profit & Loss Account.<\/li>\n<\/ol>\n\n\n\n

    This makes tax audit reporting more structured, digital and data-driven.<\/p>\n\n\n\n

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    15. Charitable Trust Registration: Form 10A Becomes Form 104<\/h2>\n\n\n\n

    For charitable and religious institutions, provisional registration under the old framework was applied through Form 10A.<\/p>\n\n\n\n

    Under the Income-tax Act, 2025:<\/p>\n\n\n\n

    Purpose<\/th>Old Form<\/th>New Form<\/th><\/tr><\/thead>
    Provisional registration of charitable trust \/ institution<\/td>Form 10A<\/td>Form 104<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n

    Existing approvals or registrations granted under the Income-tax Act, 1961 generally continue, provided they are not inconsistent with the Income-tax Act, 2025. This continuity flows from the repeal and savings framework of Section 536.<\/p>\n\n\n\n

    If an application was filed during FY 2025-26 and remained pending on 31 March 2026, it will be disposed of under the Income-tax Act, 1961. A fresh application is not required merely because the new Act has commenced.<\/p>\n\n\n\n

    For trust, society, RWA and charitable institution audit support, refer to our RWA, Society, CGHS and Trust Audit Services<\/a>.<\/p>\n\n\n\n

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    16. Consolidated Mapping of Old Forms and New Forms<\/h2>\n\n\n\n
    Purpose<\/th>Old Form<\/th>New Form under Income-tax Rules, 2026<\/th><\/tr><\/thead>
    PAN application \u2014 Indian individual<\/td>Form 49A<\/td>Form 93<\/td><\/tr>
    PAN application \u2014 Indian company \/ entity<\/td>Form 49A<\/td>Form 94<\/td><\/tr>
    PAN application \u2014 foreign individual<\/td>Form 49AA<\/td>Form 95<\/td><\/tr>
    PAN application \u2014 foreign entity<\/td>Form 49AA<\/td>Form 96<\/td><\/tr>
    TAN application \u2014 Government<\/td>Form 49B<\/td>Form 134<\/td><\/tr>
    TAN application \u2014 other than Government<\/td>Form 49B<\/td>Form 135<\/td><\/tr>
    Declaration where PAN is not available<\/td>Form 60<\/td>Form 97<\/td><\/tr>
    Half-yearly statement of declarations<\/td>Form 61<\/td>Form 98<\/td><\/tr>
    Lower \/ nil withholding certificate<\/td>Form 13<\/td>Form 128<\/td><\/tr>
    Self-declaration for no TDS<\/td>Form 15G \/ Form 15H<\/td>Form 121<\/td><\/tr>
    Relief for salary arrears<\/td>Form 10E<\/td>Form 39<\/td><\/tr>
    Foreign remittance information<\/td>Form 15CA<\/td>Form 145<\/td><\/tr>
    CA certificate for foreign remittance<\/td>Form 15CB<\/td>Form 146<\/td><\/tr>
    Tax audit report<\/td>Form 3CA \/ 3CB \/ 3CD<\/td>Form 26<\/td><\/tr>
    Provisional registration of charitable trust<\/td>Form 10A<\/td>Form 104<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n
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    17. Practical Compliance Checklist<\/h2>\n\n\n\n

    Before filing any form after 1 April 2026, taxpayers and businesses should check:<\/p>\n\n\n\n

      \n
    1. Whether the transaction relates to FY 2025-26 or Tax Year 2026-27.<\/li>\n\n\n\n
    2. Whether the form is being filed for an old Assessment Year or a new Tax Year.<\/li>\n\n\n\n
    3. Whether any application was already pending as on 31 March 2026.<\/li>\n\n\n\n
    4. Whether accounting, payroll, ERP and TDS software have been updated with new form numbers.<\/li>\n\n\n\n
    5. Whether the correct PAN \/ TAN \/ TDS \/ remittance form has been selected.<\/li>\n\n\n\n
    6. Whether foreign remittance documents are supported by Form 145, Form 146 or AO certificate, as applicable.<\/li>\n\n\n\n
    7. Whether Form 26 applies, or the older tax audit forms still apply.<\/li>\n\n\n\n
    8. Whether trust registration and approval records under the old Act have been preserved properly.<\/li>\n<\/ol>\n\n\n\n
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      18. Common Mistakes to Avoid<\/h2>\n\n\n\n

      Taxpayers should avoid the following mistakes during transition:<\/p>\n\n\n\n