
Quick answer
What the Department found
Intelligence and analysis of outward remittance data identified entities that sent large sums abroad over three years. A search uncovered a nationwide network linked to shell charitable trusts that provided bogus accommodation entries for fake donations. Many remitting entities had not filed returns, or reported turnover with no apparent link to the amounts remitted. Stated purposes such as freight, software imports and consultancy did not match the entities' profiles, and several were not operating from their registered addresses. A small group of professionals issued a disproportionately large number of Form 15CB certificates, and the overseas recipients formed a concentrated cluster.
Form 15CB under the new rules
Due-diligence checklist before certifying a remittance
Know the remitter
Check that the entity files returns and that its turnover and business profile support the size of the remittance. Check the underlying transaction
Obtain and review the invoice, agreement, purchase order and proof of services or goods actually received. Verify the payee
Confirm the recipient's identity, country, tax residency certificate and Form 10F where DTAA benefit is claimed. Determine taxability properly
Analyse the nature of the payment under the Act and the DTAA, and work out the correct withholding. Keep a working file
Retain copies of documents and your analysis for every certificate, so you can respond if asked. Watch for red flags
Repeated remittances to the same overseas parties, new entities with large remittances, mismatched purposes or addresses, and pressure to certify quickly.
What remitters should do
Frequently Asked Questions
Data analysis and a search found entities remitting large sums abroad with little or no reported turnover, linked to shell entities and bogus accommodation entries, with Form 15CB certificates issued without adequate due diligence.
394 entities, including 117 in land-border States, and 36 professionals, according to the press release of 18 August 2026.
Under the Income-tax Rules, 2026, the accountant's certificate corresponds to Form 146 under Rule 220.
To exercise due care, diligence and professional judgment and examine the underlying transactions and documents before issuing remittance certificates.
The accountant should not issue the certificate until the underlying transaction and its taxability can be verified from the books and documents. Certifying without examination exposes the professional to inquiry, as the Department's verification of 36 professionals shows.



