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15CA/15CB Automation: How to File Form 145 and 146 Faster in 2026

Form 15CA and 15CB are now Form 145 and 146. Which part applies, the filing process, common errors and how to automate foreign remittance compliance in bulk.

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15CA/15CB automation showing Form 145 and Form 146 replacing Form 15CA and 15CB for foreign remittances

15CA/15CB Automation: How to File Form 145 and 146 Faster in 2026

Every payment to a non-resident, whether software licence fees, consultancy, royalty or interest, needs a Form 15CA declaration before the bank will release it, and many need a CA's Form 15CB. Since 1 April 2026 these forms have new names under the Income-tax Act, 2025: Form 145 (formerly 15CA) and Form 146 (formerly 15CB).

For a company making dozens of remittances a month, filling these one by one on the portal is slow and error-prone. This guide explains what changed, which part applies, and which steps you can automate.

Note

Quick answer: Form 145 (old 15CA) is the remitter's declaration and Form 146 (old 15CB) is the CA's certificate on taxability and TDS. File Form 145 before every taxable remittance to a non-resident. Part A covers taxable payments up to ₹5 lakh in the year; Part B, payments above ₹5 lakh backed by an Assessing Officer's certificate; Part C, payments above ₹5 lakh with a Form 146; Part D, payments that are not taxable. Automation means generating the forms in bulk from your ERP payables data and uploading them through the portal's offline utility.

What changed from 1 April 2026

ItemIncome-tax Act, 1961Income-tax Act, 2025
Remitter's declaration Form 15CA Form 145
CA certificate Form 15CB Form 146
Rule Rule 37BB Rule 220
Duty to furnish information Section 195(6) Section 397(3)(d) [VERIFY]
Penalty for not furnishing Section 271-I, ₹1 lakh Section 462, up to ₹1 lakh [VERIFY]
TDS on payments to non-residents Section 195 Section 393(2)
Treaty declaration Form 10F Form 41
Quarterly TDS return (non-residents) Form 27Q Form 144

Two other changes matter for automation:

  • UDIN in real time. Forms 145 and 146 carry the CA's UDIN, which is checked against the ICAI system when you file.
  • Part B stands alone. If you hold an Assessing Officer's certificate and file Part B, you do not also need Part C or Form 146.

Which part of Form 145 applies?

Decision chart for choosing Form 145 Part A, B, C or D for a foreign remittance
SituationForm 145 partForm 146 (CA certificate)?
Taxable; total to the recipient in the tax year up to ₹5 lakh Part A No
Taxable; above ₹5 lakh; AO certificate under Section 395 Part B No
Taxable; above ₹5 lakh; no AO certificate Part C Yes
Not taxable in India (for example, most import payments) Part D No
Individual remitting under LRS, IFSC units, or a purpose code on the exempt list Not required No

Note

Under the old Rule 37BB, a list of 33 payment types was exempt. The new rule appears to link the exemption to RBI purpose codes. Confirm the list in Rule 220 before relying on it.

How to file Form 145 and 146 on the portal

1. Add your CA on the e-filing portal under Authorised Partners. 2. CA files Form 146 online or through the offline utility, signs with a DSC and quotes the UDIN. 3. You file Form 145: e-File → Income Tax Forms → "Forms as per Income Tax Act 2025" → Form 145. Choose the part and tax year. Part C picks up details from Form 146 using its acknowledgement number. 4. E-verify with DSC or EVC and download the acknowledgement. 5. Give it to your bank (authorised dealer), which can now receive it electronically.

A filed Form 145 cannot be edited. If you find an error, withdraw it within 7 days and file again.

Common errors that delay remittances

ErrorWhat happensPrevention
Wrong part selected Bank rejects the form Apply the decision table above for each payment
Wrong nature of remittance or purpose code Mismatch with the bank's Form A2 Maintain a mapping from expense type to RBI purpose code
Treaty rate claimed without TRC or Form 41 Short deduction, interest, disallowance Track document validity per vendor
Wrong exchange rate TDS under- or over-deducted Apply the prescribed SBI TT buying rate consistently
Grossing-up missed when you bear the tax Short deduction Flag net-of-tax contracts in the vendor master
₹5 lakh limit tracked per remittance Wrong part used Track the running total per recipient per tax year
Form 145 data not matching Form 144 TDS return defaults Reconcile each quarter

15CA/15CB automation: what you can automate

TaskManual todayAutomated
Form data entry Retyped from invoices on the portal Bulk forms generated from ERP payables data and uploaded via the offline utility
Part selection Judged per payment Rules apply the ₹5 lakh running total, taxability and certificate status
Treaty rates Looked up each time DTAA rate table with TRC and Form 41 expiry alerts
Purpose codes Chosen by hand Mapped from expense or GL code
CA certificates Tracked by email Status of each Form 146 and UDIN tracked in one list
Withdrawals Easy to miss Alert within the 7-day window
Returns Separate exercise Form 145 data reconciled with Form 144 and Form 131
Audit trail Scattered PDFs Invoice, Form 146, Form 145, TRC and bank advice stored together

The e-filing portal has no public API for these forms, so bulk filing in practice means generating files in the portal's schema and uploading them through the offline utility.

Keep every Form 145 and 146 in one place with Figment

NoticeCPC, Figment's tax notice management software, includes dedicated Form 145 and Form 146 tabs alongside Income Tax, GST and ITAT notices, so your team can see every foreign remittance form across PANs in one place. The TDS on those remittances flows into Form 144 through TaxCPC, Figment's TDS return filing software, with live TRACES validation. Paying dividends to non-residents? See our guide to TDS on dividend.

Frequently Asked Questions

From 1 April 2026, Form 15CA is Form 145 and Form 15CB is Form 146 under the Income-tax Act, 2025 and Rule 220 of the Income-tax Rules, 2026.

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