Description: A complete guide to Form 15CA and 15CB (now Form 145/146) for NRIs, covering when both forms apply, exemptions, and how to avoid the ₹1 lakh penalty.

Not every remittance out of India needs both forms. Some transactions need just a self-declaration, others need a Chartered Accountant’s certificate on top of it, and some are exempt entirely. Getting this distinction wrong is one of the most common reasons NRI remittances get delayed or rejected at the bank.

Why Every Remittance From India Needs This Compliance Check

Whenever money moves from India to a non-resident or a foreign account, the bank needs to confirm two things before processing it: whether the payment is taxable under Indian law, and whether the correct tax has been deducted or accounted for. Form 15CA is the remitter’s own declaration answering this, filed on the income tax portal before the transfer. Form 15CB is a separate certificate from a practicing CA, required only for certain remittances, confirming the applicable TDS rate, DTAA treatment, and tax position. Not every transaction needs both — which one applies depends entirely on the amount and taxability of the remittance.

What Changed: 15CA/15CB Are Now Form 145/146

As of 1 April 2026, Form 15CA has been renamed Form 145, and Form 15CB has been renamed Form 146, under Section 393(2) of the Income-tax Act, 2025. This is largely a renaming and restructuring exercise — the ₹5 lakh threshold, the four-part structure, and the Rule 37BB exemption list all remain substantially the same. What matters is the remittance date, not when the underlying transaction started: transfers completed before 31 March 2026 use the old 15CA/15CB, and anything from 1 April 2026 onward uses Form 145/146.

Which Part of the Form Actually Applies to You

The form is filed in one of four parts, and picking the right one depends on your remittance amount and tax position:

• Part A — remittance is taxable but stays under ₹5 lakh for the financial year → no CA certificate needed
• Part B — remittance is taxable, exceeds ₹5 lakh, but you’ve already obtained an order or certificate under Section 195(2)/195(3)/197 from your Assessing Officer → no Form 146 needed either
• Part C — remittance is taxable and exceeds ₹5 lakh, with no prior AO order → Form 146 from a CA is mandatory before this part can be filed
• Part D — remittance isn’t chargeable to tax in India at all, under the Act or an applicable DTAA

Most routine NRI remittances above ₹5 lakh fall under Part C, which is exactly why the CA certificate step trips people up most often.

The Transfer NRIs Do Most: NRO to NRE or Foreign Account

Moving your own money from an NRO account to your NRE account or a foreign bank account doesn’t involve TDS, since it’s your own funds, not a payment to a third party. Banks still treat this as a remittance to a non-resident for their internal compliance and require the same forms before processing it. Typical documents banks ask for alongside Form 145/146 include:

• Application for outward remittance from the NRO account
• Form 146 (CA certificate) and Form 145 (remitter declaration), both filed on the income tax portal
• PAN of the NRI account holder
• Bank statements supporting the source of funds
• A source-of-funds declaration, in some cases

When You’re Exempt (and Why Your Bank Might Still Ask Anyway)

Rule 37BB exempts several categories from needing Form 145/146 entirely, including remittances under the Liberalised Remittance Scheme that don’t require prior RBI approval, within the USD 250,000 annual limit, along with certain import payments and specified categories under Sections 10(23), 10(23B), and 10(31). Even when a transaction technically qualifies, banks sometimes still request the forms as part of their own internal risk process. It’s worth checking with your bank’s NRI desk directly rather than assuming the legal exemption alone will be enough.

The ₹1 Lakh Penalty You’re Actually Trying to Avoid

Section 271-I imposes a ₹1 lakh penalty per form for non-filing or for furnishing inaccurate information in Form 145 or 146. This applies whether you skip filing entirely or file with incorrect details, and it applies per form, not per transaction — meaning both a bad Form 145 and a bad Form 146 on the same remittance can each attract their own penalty.

Step-by-Step Remittance Timeline

1. Gather documents: invoice/contract details, PAN, Tax Residency Certificate and Form 10F (if DTAA relief applies), and bank statements
2. If Form 146 is required, your CA reviews the transaction and certifies TDS treatment — typically 1-2 working days for straightforward cases, 3-5 days if DTAA or Permanent Establishment analysis is involved
3. File Form 145 on the income tax portal, selecting the correct part and quoting the Form 146 certificate number if applicable
4. Submit the acknowledgment number and supporting documents to your bank
5. Bank processes the outward remittance, typically within 2-4 days of receiving complete documentation

Common Mistakes to Avoid

• Selecting the wrong form part. Filing under Part D when the remittance is actually taxable (common with royalty or technical service fees) is a frequent trigger for departmental scrutiny.
• Assuming exempt transactions need no bank documentation. Even Rule 37BB-exempt remittances often still require paperwork to satisfy your bank’s internal process.
• Filing at the last minute. Form 145 must be filed before the remittance is made, not after, and rushing increases the odds of factual mismatches.
• Mismatches between remittance details and supporting documents. Inconsistent amounts, dates, or payee details across the form and your bank documentation are one of the most common causes of processing delays.

Given how directly this affects your repatriation timeline, especially alongside a property sale or a Lower TDS Certificate application, it’s worth having a CA manage Form 145/146 filing as part of the same coordinated process. Our guide on inheriting property as an NRI and guide on lower TDS certificates for NRI property sales both touch on where these forms fit into a larger repatriation sequence. Tax Vic’s NRI Tax and Property Documentation services handle Form 145/146 filing correctly, alongside the rest of your remittance compliance.

Key Takeaways

Not every remittance needs both forms, but getting the distinction wrong, filing late, or entering inaccurate details risks a ₹1 lakh penalty per form under Section 271-I. Determine which part of Form 145 applies to your transaction, confirm whether Form 146 is required, and start the process well before you need the funds transferred, rather than scrambling once a deadline is already close.

Need help with this? If you need help filing Form 145/146 correctly for your next remittance, book a 15 min free consultation with Tax Vic.

Author: CA Reetu Bhandari

Published: 18 December 2022

Last Reviewed: 9 July 2026

Disclaimer: This article is intended for general informational purposes only and does not constitute tax or legal advice. Tax provisions, forms, and procedural requirements are subject to change. Readers are advised to consult a qualified Chartered Accountant before making any decisions based on this content.