Form 15CA and 15CB: The Remittance Paperwork, Now Forms 145 and 146
Form 15CA is the remitter's online declaration that tax has been considered on a payment leaving India. Form 15CB is the chartered accountant's certificate backing that declaration for taxable remittances above the threshold. From 1 April 2026, under the Income-tax Act, 2025, Form 15CA is renumbered Form 145 and Form 15CB is renumbered Form 146. The substance carries over; some fields are new. No bank will wire your property sale proceeds abroad without them.
Have your own CA or lawyer read this against your papers before you act on it. We report the rule. The person who has seen your position is the one who can tell you what it means for you.
What each form does
Form 15CA (now Form 145) is filed by the person sending the money: you, the NRI account holder, or any remitter paying a non-resident. It declares the nature of the remittance, the amount, and the tax position. It is filed on the income tax e-filing portal before the bank executes the transfer.
Form 15CB (now Form 146) is a certificate from a practising chartered accountant. The CA examines the source of funds, the taxability of the remittance, the rate applied, the DTAA position if claimed, and certifies the details. It is the CA's signature on the line, with a UDIN. The bank relies on it; so does the tax department.
The renumbering is confirmed by the Income Tax Department: the portal lists Form 145 with the note "earlier Form 15CA," and the department's FAQs say the same. Banks and CAs will use the old names in conversation for years. The portal will not.
The four parts of Form 145 (old 15CA)
| Part | When it applies |
|---|---|
| Part A | Taxable remittance, total in the financial year up to Rs 5 lakh |
| Part B | Taxable remittance above Rs 5 lakh, covered by a lower/nil TDS order or certificate |
| Part C | Taxable remittance above Rs 5 lakh, backed by a CA certificate in Form 146 (old 15CB) |
| Part D | Remittance not chargeable to tax in India |
Property sale proceeds and NRO balance transfers almost always travel under Part C with a Form 146, or Part D where the remittance is not chargeable. The CA decides which, on paper, with reasons. Confirm the current thresholds on the portal before filing; the structure above carried over from Rule 37BB of the old regime.
Who does not need the forms
The rules carve out a specified list of remittance purposes, 33 categories under the old Rule 37BB, where no Form 15CA/15CB is needed at all. The list covers items like imports, certain travel and education remittances, and other current-account payments by residents. Two practical points for NRIs:
- Transfers between your own NRE accounts, or outward remittance from an NRE account, do not need the forms. NRE balances are repatriable by design.
- NRO remittances under the USD 1 million scheme do need the forms. Banks ask for Form 146 even where the funds are post-tax, because the certificate is their audit cover.
Do not rely on a blog list of exemptions, including this one. Check the current rule on the portal or have the CA cite it in the certificate.
Step-by-step e-filing
- The remitter logs in to the e-filing portal and assigns Form 146 (old 15CB) to a CA under "My CA," authorising that CA for the form and the year.
- You give the CA the full file: source-of-funds proof (sale deed, TDS certificates, bank statements), PAN, passport, the remittance amount, the destination account, and the purpose.
- The CA files Form 146 online with a digital signature and generates the UDIN.
- You (or the CA on your behalf) file Form 145 in the correct part, pulling in the Form 146 acknowledgment number.
- Download both acknowledgments. Submit them to the bank with Form A2 (the FEMA outward remittance declaration) and the bank's own repatriation request form.
- The bank's trade or NRI desk verifies, then executes the wire.
Each remittance needs its own filing. Splitting a large transfer into tranches means a fresh Form 145, and often a fresh 146, per tranche.
What changed under the Income-tax Act, 2025
- Numbering: 15CA becomes 145, 15CB becomes 146, in force 1 April 2026.
- Section references inside the forms now point to the 2025 Act's TDS provisions (section 393(2) instead of section 195).
- Reported fields expanded: tax identification number in the destination country, fuller remittee address and bank details, and more granular remittance sub-codes.
- The Rs 5 lakh part-structure and the exemption-list design carried over in substance.
If a bank officer or an older guide insists the forms are "15CA/15CB," they mean Forms 145/146. Filing under the old form numbers is not possible on the portal for transactions on or after 1 April 2026.
Where this goes wrong
- Purpose code mismatch. Form A2 says one purpose code, Form 145 says another, and the bank's compliance desk rejects the file. This is the single most common rejection. Fix the codes before filing, not after.
- The CA certifies "not chargeable" under Part D for sale proceeds where capital gains tax applied. The bank escalates, the file dies, and the remitter starts over under Part C.
- Name mismatches between the PAN, the passport, and the bank account. One spelling difference is enough for a rejection.
- The Form 146 is filed but never linked in the Form 145, so the acknowledgment the bank sees is incomplete.
- The remitter files for the full year's transfers in one form, then tries to remit in tranches. Banks want one form per remittance.
- A CA who has never certified an NRO property remittance treats it like a vendor payment and picks the wrong sub-code. Banks notice.
What it costs to skip the forms
Remitters treat these as bank paperwork. The Income-tax Act treats them as an information return with a penalty attached.
Under Section 271-I of the Income-tax Act, 1961, a person required to furnish information under Section 195(6) who fails to furnish it, or furnishes inaccurate information, may be directed by the Assessing Officer to pay a penalty of one lakh rupees. The penalty attaches per default, so a remitter who ran four tranches without filing is looking at four defaults rather than one.
Two things soften it. Section 273B bars the penalty where the person proves reasonable cause for the failure, and tribunals have accepted that where the underlying payment was genuinely outside the charge. And the penalty is on the person responsible for paying the non-resident, which in an NRO repatriation is the remitter, not the bank. The bank simply refuses to move the money, which is why most people never reach the penalty stage.
The section survives the renumbering into the Income-tax Act, 2025 in substance. Ask your CA to cite the operative provision in the certificate for the year you are filing rather than assuming the old number.
FAQ
Are Form 15CA and 15CB still called that in 2026? The forms are renumbered: Form 145 replaces 15CA and Form 146 replaces 15CB from 1 April 2026 under the Income-tax Act, 2025. Same job, new numbers, some new fields.
Who files which form? The remitter files Form 145. A practising CA files Form 146. For an NRI moving property sale proceeds, the CA prepares both in most cases and the NRI authorises the CA on the portal.
Is Form 146 (15CB) always required? No. It is required for taxable remittances above Rs 5 lakh in the year that are not covered by a lower/nil TDS order. Exempt-list remittances and NRE transfers need neither form. Confirm against the current rule.
Do I need the forms to move money from NRO to NRE? Yes. Banks treat NRO-to-NRE transfers like outward remittances under the USD 1 million scheme and ask for Forms 145 and 146.
Can the bank remit without the forms? For NRO property proceeds, no. The authorised dealer bank is required to collect the declarations before remitting.
How long does filing take? With documents ready, a CA can file Form 146 and Form 145 in two to four working days. The bank's processing adds two to ten working days.
What happens if the form has an error after the wire went out? Form 145 can be withdrawn within a limited window. Past that, corrections get messy and may need the assessing officer. Get it right before the bank executes.
We file these for a living
66 MG Road's tax and repatriation team handles the entire chain for NRI property sales: TDS reconciliation, Form 146 certification through partner CAs who do this every week, Form 145 filing, purpose codes matched to Form A2, and follow-through until the wire lands. Teams in Delhi NCR and Bangalore. Itemized billing. See tax and repatriation services.
Saurabh Garg, founder, 66 MG Road
Sources
- Income Tax e-filing portal, Form 145 user guide: https://www.incometax.gov.in/iec/foportal/newformpage/forms/form145-UM
- Income Tax Department, Form 145 (earlier Form 15CA) FAQs: https://www.incometaxindia.gov.in/documents/d/guest/form-145-faqs
- Income Tax e-filing portal, Income Tax Forms: https://www.incometax.gov.in/iec/foportal/help/all-topics/e-filing-services/income-tax-forms
- RBI Master Circular on Remittance Facilities for Non-Resident Indians: https://www.rbi.org.in/commonman/english/scripts/Notification.aspx?Id=843
- Income Tax Department, Section 271-I (penalty of one lakh rupees for failure to furnish information under section 195(6), or furnishing inaccurate information): https://www.incometaxindia.gov.in/w/section-271-i
- TaxGuru, Section 271I penalty for failure in furnishing Form 15CA and Form 15CB (per-default penalty; section 273B reasonable-cause relief): https://taxguru.in/income-tax/section-271i-penalty-failure-furnishing-form-15ca-form-15cb.html