Form 145 & Form 146 vs Form 15CA & 15CB: what actually changed?

Last updated 3 August 2026

Full Answer

A CA firm in Bengaluru got a panicked call from a client in July 2026. The client's bank had sent back a remittance instruction referencing "Form 145" instead of the familiar 15CA, and the client assumed a new compliance requirement had appeared out of nowhere, possibly one they had missed. It took the CA five minutes to explain that nothing new had been introduced. The form had simply been renumbered as part of a nationwide recodification of the entire Income Tax Act. This is the confusion this article exists to clear up: what changed between 15CA/15CB and Form 145/146, and, just as importantly, what did not.

The renumbering did not happen in isolation. The Income Tax Act, 2025 replaced the Income Tax Act, 1961 in its entirety, and as part of that exercise, provisions and forms across the whole statute were renumbered and reorganized, not rewritten with new rules. Form 15CA and Form 15CB were two of the many forms affected. Under the old law, 15CA sat under Section 195(6) and 15CB under Rule 37BB of the Income Tax Rules. Under the new law, both forms and their governing provisions moved: Form 145 is now anchored in Section 395 of the Income Tax Act, 2025, and the corresponding procedural rule is Rule 220 of the Income Tax Rules, 2026. The broader definitional and procedural scaffolding around foreign remittance compliance, including provisions previously scattered across the 1961 Act, was consolidated under Sections 393, 397, and 462 of the new Act. None of this changed why the forms exist or what they ask you to certify.

Here is what is genuinely identical between the old and new regime. The Rs 5 lakh threshold above which a CA certificate is mandatory for a taxable remittance has not moved. The sequence has not changed either: the CA issues the certificate first, generating an acknowledgement number, and the remitter's declaration is filed second, referencing that number, exactly as 15CB preceded 15CA. The UDIN requirement for every certificate issued by a practicing CA still applies, and it is still verifiable on the ICAI UDIN portal. The eligibility rule for who can issue the CA certificate is also unchanged: only a Chartered Accountant holding a valid, active Certificate of Practice from ICAI can sign it. A retired practice certificate or a non-CA tax consultant still cannot issue Form 146, exactly as they could not issue 15CB.

What this means practically is that there is very little for a business or an NRI remitter to actually do differently. If you were sending money abroad in March 2026 and understood the 15CA/15CB process, you already understand the Form 145/146 process, because it is the same process. Shunya's service and internal workflow have not changed either; our CAs review the same underlying documents, apply the same TDS and DTAA analysis, and issue a certificate that now happens to be labelled Form 146 instead of 15CB, followed by the remitter's Form 145 instead of 15CA. The paperwork's name changed. The diligence behind it did not.

The one place this transition needs a little care is remittances that straddle the changeover date. Remittances processed and acknowledged before 1 April 2026 keep their original Form 15CA and Form 15CB acknowledgement numbers exactly as issued; there is no need to reissue or relabel them. Remittances processed on or after 1 April 2026 are filed under Form 145 and Form 146 from the outset. Banks reconciling older transactions against newer ones should expect to see both form numbers in circulation for some time, and that is expected behaviour, not an error on either side.

This article is for general information only. For your specific remittance, consult a practicing CA.