Form 145 Income Tax 2025: Purpose, Applicability & Form 15CA Substitution

Form 15CA has been replaced by Form 145, effective from 1st April 2026, shifting the compliance requirement from Section 195 of the Income Tax Act to Sections 393, 395, 397, and 462 of the Income Tax Act, 2025, read with Rule 220 of the Income Tax Rules, 2026. If you’re an Indian company paying overseas vendors, an individual remitting funds abroad, or a bank processing outward payments on behalf of clients, this form now sits between you and every foreign remittance. This article covers what Form 145 is, who needs to file it, the step-by-step process, and the penalties for getting it wrong. 

Key Due Dates for Form 145

Important note: Form 145 is an event-based form - it must be filed for each remittance. There is no annual consolidated filing option.

What is Form 145?

Form 145 is a mandatory declaration which any person or entity is responsible for paying a non-resident or a foreign company must file before remitting funds outside India. It gives the Income Tax Department the authority into remittance which is chargeable to tax in India, supports correct tax deduction at source as per Section 393(2), followed by cross verification against related forms (Form 146, Form 144 and Form 147) through integration with the Department’s ITBA system. 

Why was Form 145 introduced?

Rule 220 states that every person responsible for paying a non-resident (not being a company) or a foreign compay must furnish Form 145 before remitting the payment this includes any category of Authorised Signatory, Representative and Taxpayer handling such a remittance. Filing is required separate for each remittance. Along form 145 cannot cover various payments. 

Perhaps, three categories of payments are exempt form this requirement. 

How to File Form 145 Online - Step-by-Step Guide

Form 145 can be filed in two modes: Online through the Income Tax e-filing portal, or Offline using the downloadable utility. The online mode is recommended for most users. Here is the complete step-by-step process:

For Part A, Part B, and Part D (no CA certificate involved):

1. Log in to the Income Tax e-filing portal at www.incometax.gov.in using your User ID and password
2. From your Dashboard, go to: e-File > Income Tax Forms > File Income Tax Forms
3. Click the tab "Forms as per Income Tax Act 2025"
4. Search for or select "Form 145"
5. Select the mode as "Online" and choose the relevant Tax Year, then click Continue
6. Click "Let's Get Started" - Form 145 opens. Select the applicable Part (A, B, or D)
7. Fill in all mandatory fields: remitter details, remittee details (including TIN), remittance details, income nature, TDS details
8. Review the completed form on the Preview page - verify all details carefully
9. Click "Proceed to e-Verify" and select your verification method (DSC or EVC)
10. Click "Yes" to submit. Download and save the acknowledgement receipt
11. Provide a copy of the filed Form 145 and acknowledgement to your bank (Authorised Dealer) before the remittance is processed
12. For Part C (CA certificate / Form 146 required):
    1. First, add your CA on the portal: My Account > Authorised Partners > My Chartered Accountants > Add CA (enter CA membership number and select Form 146)
    2. The CA logs in to the e-filing portal and files Form 146 (CA certificate) - certifying the taxability, DTAA applicability, and TDS rate
    3. The CA e-verifies Form 146 using DSC
    4. You log back in and go to File Form 145 > Select Part C
    5. Enter the acknowledgement number of the verified Form 146 - the system pre-fills Part C details from Form 146
13. Complete the remaining fields, review, e-verify, and submit
14. Provide the form and acknowledgement to your AD bank

What is the structure of Form 145? 

What are the penalties for not filing Form 145?

Filing Form 145 is not optional - it is a legal requirement under the Income Tax Act, 2025. The consequences of non-compliance are clear:

1. Penalty of up to ₹1 lakh under Section 462 of the Income Tax Act, 2025 if Form 145 is not filed or if inaccurate information is furnished
2. Your bank (Authorised Dealer) will not process the foreign remittance without the Form 145 acknowledgement, so non-filing directly blocks the transaction
3. If TDS is incorrectly calculated or not deducted, the shortfall will be treated as a tax default, potentially triggering demands and interest under Section 220
4. The same penalty applies for incorrect information, not just for missing the form entirely

What are the documents that are required to File Form 145 ?

1. PAN of the remitter (person making the payment)
2. TAN of the remitter
3. Name, address, and Tax Identification Number (TIN) of the foreign recipient (remittee)
4. Country of residence of the remittee and Tax Residency Certificate (TRC) - if DTAA benefit is claimed
5. Amount of remittance, currency, and purpose code
6. Nature of income (selected from 65 remittance categories in the form)
7. BSR Code (7-digit) of the bank branch from which the remittance is made
8. ITDREIN (Income Tax Department Reporting Entity Identification Number) of the remitter
9. TDS details: applicable rate, amount deducted, date of deduction
10. Authorised Dealer (AD) bank details - not required separately if the bank making remittance is also the AD
11. For Part B: AO certificate / order reference under Section 395(1) or 395(2)
12. For Part C: Acknowledgement number and UDIN of Form 146 filed by the CA