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

Form 145 is the declaration filed for remittances made to non-residents. Earlier Form 15CA of the Income Tax Act, 1961, Form 145 is now dealt under section 395 of the Income Tax Act, 2025. Form 15CA is replaced by Form 145 with effect from 1st April, 2026.

What is Form 145?

Form 145 is a mandatory declaration filed for making a payment to a non-resident or to a foreign company, before such remittance is made. It is governed by Sections 393, 395, 397, and 462 of the Income Tax Act, 2025 and Rule 220 of the Income Tax Rules, 2026.

The following table demonstrates the appropriate form number, enforcing sections and rules under the Income Tax Act 1961 and the 2025 Act.

Why was Form 145 introduced?

What Was Form 15CA?

• Form 15CA was introduced under Section 195(6) of the Income Tax Act, 1961, read with Rule 37BB of the Income Tax Rules, 1962. 
• It was a self-declaration document required to be filed before a foreign remittance to a non-resident or a foreign company.

Why Did the Government Replace It?

Since the Income Tax Act 2025 superseded the 1961 Act, all the forms issued under the old Act have been replaced to align with the modern compliance requirements.

Who should file Form 145?

Form 145 must be filed by every person responsible for paying a non-resident or a foreign company before remitting funds outside India, as per Rule 220 of the Income Tax Rules, 2026.

This includes:

• Indian companies paying fees, royalties, interest, or dividends to foreign entities
• Indian individuals remitting money abroad for services, professional fees, or investments
• Businesses paying overseas consultants, software vendors, or licensors
• Banks and financial institutions make payments on behalf of clients to non-residents
• Any taxpayer, Authorised Signatory, or Representative Assessee required to report foreign remittances

The requirement applies to each individual remittance separately. You cannot submit one Form 145 for multiple payments. Every transaction requires its own filing.

When is Form 145 not required?

• For certain payments exempt under the Income Tax Act, 2025, the Form 145 requirement does not apply. 
• Every foreign remittance made by an individual, for a sum that is not chargeable under the Income Tax Act, and which does not require prior RBI approval, is exempted from the Form 145 requirements
• Also, the transactions undertaken by IFSCs under section 147 of the 2025 Act are exempted from Form 145 requirements. 
• Along with the above, the following transactions are exempted from Form 145 requirements, if they are nor chargeable under the Income Tax Act, 2025 

Understanding the Four Parts of Form 145

Form 145 has four parts. They are:

• Part A - Taxable Remittances up to ₹5 Lakh
• Part B - Taxable Remittances Above ₹5 Lakh, where a certificate from the Assessing Officer is obtained
• Part C - Taxable Remittances Above ₹5 Lakh, where Form 146 from a CA is obtained
• Part D - Non-Taxable remittances

Part A - Taxable Remittances up to ₹5 Lakh

Part A applies when the remittance is taxable under the Income Tax Act, 2025, and the total remittances to that recipient during the tax year do not exceed ₹5 lakh. The following details must be furnished in Part A.

• Particulars of the remitter (name, PAN, address, contact details)
• Particulars of the remittee (name, address, TIN in country of residence)
• Details of remittance: amount, country, bank details, BSR code
• Nature of income (selected from the list of 65 remittance categories)
• TDS details: rate, amount, and date of deduction
• RBI Purpose Code
• Declaration and signature of the remitter

Part B - Taxable Remittances Above ₹5 Lakh (AO Certificate)

Part B applies when the remittance is taxable, the aggregate amount exceeds ₹5 lakh during the tax year, and a lower tax deduction certificate has been obtained under section 395 of the 2025 Act, from the Assessing Officer (AO).

Part B includes all the fields from Part A plus:

• Details of the AO certificate / lower TDS order obtained
• Section and rate of TDS as per the certificate

Part C - Taxable Remittances Above ₹5 Lakh (CA Certificate / Form 146)

Part C is the most commonly used section for large business remittances. It applies when the remittance is taxable, the aggregate exceeds ₹5 lakh, and a certificate from a Chartered Accountant (Form 146 - the new Form 15CB) has been obtained instead of an AO order.

Part C is the most detailed section and additionally requires:

• Details of the Chartered Accountant who has issued Form 146
• Acknowledgement number of the verified Form 146
• UDIN (Unique Document Identification Number) of the CA certificate
• Taxability assessment under the Act - without DTAA consideration
• Taxability under the applicable DTAA (if any) including the relevant article and treaty rate
• Tax Residency Certificate (TRC) details if DTAA benefits are being claimed
• Form 41 (lower TDS application), if applicable

Part D - Non-Taxable Remittances

Part D is filed when the remittance is NOT taxable under the Income Tax Act, 2025 at all - for example, payments for goods (imports), certain capital account transactions, or remittances specifically exempted by rule.

Part D contains:

• Particulars of the remitter and remittee
• Details of the remittance
• Declaration for non-taxability
• Declaration by the remitter confirming non-taxability

Documents and Information Required to Fill 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

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 Form 146 and How does it relate to Form 145?

Form 146 is the CA certificate under the Income Tax Act, 2025 - it replaces the old Form 15CB. It is issued by a Chartered Accountant registered on the Income Tax e-filing portal and certifies the following:

• The nature and purpose of the remittance
• Taxability of the payment under the Income Tax Act, 2025
• Taxability under the applicable DTAA (Double Taxation Avoidance Agreement)
• Applicable TDS rate and the amount to be deducted
• Details of the Tax Residency Certificate (TRC) of the remittee
• UDIN (Unique Document Identification Number) for authenticity verification

Form 146 is required only for Part C of Form 145 - i.e., taxable remittances above ₹5 lakh where the remitter does not have an AO-issued certificate. 

Form 145 vs Form 15CA - Comparison Table

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:

• 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
• Your bank (Authorised Dealer) will not process the foreign remittance without the Form 145 acknowledgement, so non-filing directly blocks the transaction
• 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
• The same penalty applies for incorrect information, not just for missing the form entirely

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.

Also Read:
1. Form 121
2. Form 124
3. Form 130
4. Form 188