What is the difference between Form 15CA and Form 15CB?
Form 15CA (now Form 145) is your online declaration of a foreign payment, filed by you as the remitter. Form 15CB (now Form 146) is a practising CA's certificate on that payment's tax treatment. Only Part C needs 15CB, and 15CB comes first.
Form 15CA vs Form 15CB: the difference in one table
| Form 15CA (now Form 145) | Form 15CB (now Form 146) | |
|---|---|---|
| What it is | The remitter's declaration of the payment, beneficiary and TDS | A CA's certificate on taxability, treaty (DTAA) position and TDS rate |
| Who files it | You, the remitter (or someone authorised by you) | A practising CA with a valid Certificate of Practice, with a UDIN |
| When it's needed | Payments to a non-resident, unless exempt (Part A, B, C or D) | Only for Part C: taxable payments above ₹5 lakh in the year, with no Assessing Officer order |
| Order | Second: Part C quotes the 15CB acknowledgement number | First: uploaded on the portal before 15CA |
| Where | Income Tax e-filing portal | Income Tax e-filing portal, signed with the CA's digital signature |
| What your bank sees | The acknowledgement | A copy of the certificate |
Not sure which part of Form 145 applies to you? See Form 145 Part A, B, C or D: which one to file.
Full Answer
A finance manager at a Mumbai trading company told her bank's forex officer she had the 15CA done and was waiting for the bank to do the 15CB. The forex officer spent several minutes explaining that the bank does not issue 15CB. A CA does. The bank verifies 15CA. This confusion delayed a GBP 12,000 supplier payment by a day while the company arranged a CA.
The two forms are legally distinct, filed by different people, on different parts of the same portal, and one must happen before the other.
Form 15CA (now Form 145) exists under Section 195(6) of the Income Tax Act, 1961. It is a declaration the remitter, meaning you or your company, files on the Income Tax e-filing portal before making a foreign payment. You declare the purpose of the payment, the beneficiary details, the applicable TDS rate, and whether a tax treaty is being relied upon. The government uses this information to track foreign remittances and verify that TDS obligations are being met.
Form 15CB (now Form 146) exists under Rule 37BB(2) of the Income Tax Rules. It is a certificate issued by a practicing Chartered Accountant who has independently reviewed the remittance. The CA examines the nature of the payment under the Income Tax Act, determines whether TDS is applicable, identifies the applicable DTAA if relevant, verifies the TDS rate or the basis for non-deduction, and certifies all of this under their digital signature. The CA assumes professional and legal responsibility for the certificate.
The sequence is fixed. The CA issues 15CB and uploads it on the portal first. This generates a 15CB acknowledgement number. You then file Part C of 15CA and enter this acknowledgement number in the designated field. The portal will not allow you to submit Part C without a valid 15CB acknowledgement number. Attempting to reverse this sequence is impossible on the portal itself.
Not all 15CA filings require 15CB. Parts A and B of 15CA are filed by the remitter directly, without any CA involvement. Part D is also filed without 15CB. Only Part C, for taxable remittances above Rs 5 lakhs, mandates the 15CB certificate.
Shunya's CA team handles 15CA and 15CB for Indian businesses and NRIs — fully online, in 30 minutes.
Talk to a CA →Banks see both documents when you submit your remittance request. They check the 15CA acknowledgement number against the portal to confirm it exists and matches your transfer details. They also ask for the 15CB printout as a secondary verification. If any detail across the 15CA, the 15CB, and your bank's own payment instruction diverges, particularly the beneficiary name, amount, or currency, the bank will hold the transfer until the discrepancy is explained.
One ICAI regulation worth knowing: Form 15CB can only be issued by a practicing Chartered Accountant who holds a valid Certificate of Practice issued by the Institute of Chartered Accountants of India. A tax consultant or a CA who retired their Certificate of Practice cannot issue 15CB. The portal validates the CA's digital signature against the ICAI's register. If the CA's practice certificate is not active, the upload will fail.
The UDIN requirement introduced by ICAI also applies to 15CB. Every 15CB uploaded must carry a Unique Document Identification Number generated on the ICAI UDIN portal by the certifying CA. This system was introduced to prevent backdating and document fraud. When you receive a 15CB, you can verify its authenticity on the ICAI UDIN portal using the UDIN number on the certificate.
When people refer to 15CA/15CB as a combined requirement, they mean the package that Part C remittances need: the CA's certificate first, then the remitter's declaration using that certificate. Understanding them as two separate steps helps you plan the process correctly and avoid the delay of arriving at your bank with only one of them.
What is the validity period of a Form 15CB certificate? Does it expire?
Form 15CB does not have a formally prescribed expiry date under the Income Tax Rules. However, it is linked to a specific remittance transaction and loses practical relevance once you have filed the corresponding 15CA against it. Since 15CA must be filed within seven days of the remittance date, the 15CB should be used promptly after it is issued. Banks expect the 15CB and 15CA to relate to the same near-term transaction and will question certificates that appear significantly older than the payment date.
This article is for general information only. For your specific remittance, consult a practicing CA.
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