What is Form 146 and how did it replace Form 15CB?

Last updated 3 August 2026

Full Answer

In July 2026, a finance executive at a Pune-based IT services company was preparing a routine payment to their Singapore vendor, due in the first week of August. She called the company's CA and asked for the usual Form 15CB. The CA explained that for any remittance being certified on or after 1 April 2026, the document she needed was now called Form 146, issued under the new Income Tax Act, 2025, rather than Form 15CB under the old Rule 37BB. Everything else about the process, the documents required, the review the CA carries out, the certification itself, stayed exactly the same. Only the name and the legal citation changed.

Form 146 is the certificate a practising Chartered Accountant issues after independently reviewing a foreign remittance for tax compliance. The CA examines the nature of the payment, determines whether TDS applies and at what rate, checks whether a DTAA benefit is being claimed and verifies the basis for it, and then certifies all of this before the remittance is allowed to proceed. In substance, it is the same certificate 15CB always was, carrying the same professional weight and the same legal responsibility for the CA who signs it. Only the form number and the Act behind it have moved.

The change traces back to India's new Income Tax Act, 2025, which replaced the Income Tax Act, 1961 with effect from 1 April 2026. Under the new Act, the CA compliance certificate for foreign remittances is prescribed under Section 395, with the operating mechanics set out in Rule 220 of the Income Tax Rules, 2026, the direct equivalent of the old Rule 37BB. Sections 393, 397, and 462 round out the surrounding framework for remittance declarations and certifications. None of this changes what the CA is actually certifying — it only renumbers where that requirement lives in the statute.

The eligibility rule for who can issue the certificate hasn't moved either. Only a practising Chartered Accountant holding a valid Certificate of Practice from the Institute of Chartered Accountants of India can issue Form 146, exactly as only such a CA could issue Form 15CB. A tax consultant, or a CA whose Certificate of Practice has lapsed, still cannot issue it, and the portal will still validate the CA's credentials before accepting the certificate.

The UDIN requirement also continues without interruption. Every Form 146 must carry a Unique Document Identification Number generated on the ICAI UDIN portal, exactly as every Form 15CB did. UDIN is an ICAI mandate, not a rule tied to a specific tax form, so the renaming to Form 146 has no bearing on it. You can, and should, verify a Form 146's UDIN on the ICAI portal the same way you would have verified a 15CB's.

Form 146 slots into the remittance process exactly where 15CB used to. The remitter still cannot complete their own declaration, now called Form 145 in place of Form 15CA, without first obtaining the Form 146 acknowledgement from their CA and entering it into the corresponding field of Form 145. This mirrors precisely how Form 15CA used to reference the Form 15CB acknowledgement number: the sequence, the dependency, and the portal-level validation are unchanged. Only the form names are new.

If you have handled a foreign remittance any time over the last few years, nothing about your experience needs to change beyond the vocabulary. The same CA reviews the same documents, invoice or contract, TDS proof, a Tax Residency Certificate if you're claiming a treaty benefit, against the same Rs 5 lakh threshold that triggers the requirement, with the same turnaround expectations. Form 146 is Form 15CB under a new name and a new Act, not a new process.

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