Form 145 Replacing Form 15CA: Foreign-Remittance Reporting Transition Checklist

By Ravi Sisodia · Reviewed by CA Divyanshu Sengar · Updated 5 October 2026

For remittances made on or after 1 April 2026, the Income Tax Act, 2025 framework uses Form 145 in place of Form 15CA and Form 146 in place of Form 15CB. The transition file should separate remittance date, taxability and form part before the bank processes payment.

Finin2min 2-Minute Summary

• The Income Tax Department identifies Form 145 as the new equivalent of old Form 15CA and Form 146 as the equivalent of Form 15CB.
• For remittances on or after 1 April 2026, the new forms under the Income Tax Act, 2025 / Rules 2026 apply.
• Form 145 has Parts A, B, C and D depending on taxability, aggregate remittance and AO/CA certification.
• The ₹5 lakh threshold remains relevant to the part-selection framework described by the Department.
• Old Form 15CA/15CB filed for pre-1 April remittances remain tied to the proposed remittance date and actual transaction timing.

Start with remittance date and underlying accrual

The procedural form follows the law in force on the remittance date, while the taxability of underlying income can depend on the law applicable to the accrual period. This is especially important for liabilities accrued before 1 April 2026 but paid later.

Record both dates in the bank/tax instruction.

Choose the correct Form 145 part

Part A, B, C and D have different conditions. Where Part C applies, Form 146 data from the accountant feeds the remittance filing. Where an AO certificate route applies, the duplication present under the older framework has been reduced.

Do not select a part only because it produces fewer fields.

Bank control file

Keep contract/invoice, beneficiary details, country, purpose, amount, withholding analysis, DTAA position, Form 146/other certificate where relevant, Form 145 acknowledgement and bank remittance reference.

Ensure the amount/currency/purpose shown to the bank matches the tax form.

Transition case: liability accrued in March, remitted in May

A company books a foreign technical-service fee in March 2026 but remits the amount in May 2026. The Department's FAQ distinguishes the procedural reporting law from the taxability of the underlying accrual: the remittance uses the post-1 April Form 145/146 process, while the taxability analysis may still refer to the law relevant to the accrual year.

The file should show both conclusions explicitly. Banks and tax teams otherwise risk using the old form because the invoice is old, or using the new Act for every substantive tax question simply because the payment is new.

• Record accrual and remittance date.
• Separate substantive tax law from procedural form law.
• Attach Form 145/146 acknowledgement to the payment file.

Transition checklist

• Remittance date.
• Accrual period.
• Taxability/DTAA memo.
• ₹5 lakh aggregate test.
• Correct Form 145 part.
• Form 146/AO certificate where required.
• Bank and e-filing acknowledgement.

Questions readers commonly ask

What replaced Form 15CA?

Form 145 under the Income Tax Act, 2025 framework.

What replaced Form 15CB?

Form 146.

When do the new forms apply?

For remittances made on or after 1 April 2026, according to the Department FAQ.

Does pre-April accrual mean old forms are used?

Not necessarily; the procedural form follows the remittance date.

Official / primary sources

• Income Tax Department - Form 145 - Official user manual and form structure
• Income Tax Forms FAQ - Transition from 15CA/15CB to 145/146
• Form 145/146 downloads - Current utility

Disclaimer

Important: General educational and professional-reference material. Verify the current operative law, commencement notification, portal version and exact facts before acting. Educational and professional reference only; confirm the current law, rates and the facts of your case before relying on this page.