Forms 145 & 146 (ex-15CA/15CB) and the Form 128 Lower-TDS Certificate
Quick answer: Since 1 April 2026 a remittance to a non-resident is reported in Form 145 (ex-15CA), with a chartered accountant's certificate in Form 146 (ex-15CB) where the taxable remittance exceeds ₹5 lakh and no certificate or order covers it — under Section 397(3)(d) and Rule 220. Part A is for taxable remittances up to ₹5 lakh, Part B where a certificate or order exists, Part C above ₹5 lakh with Form 146, Part D where the sum is not chargeable. A lower or nil deduction certificate is now Form 128 (ex-Form 13) under Section 395, filed on TRACES at any time in the tax year. We handle the certificate, the bank's documentation and the NRI seller's side.
Last verified 4 October 2026 — rules on this page checked against the current notifications. We update it the day a rule changes.
Which part of Form 145
| Part | When | CA certificate |
|---|---|---|
| A | Taxable remittance, aggregate ≤ ₹5 lakh in the tax year | No |
| B | A lower/nil deduction certificate (Form 128) or an assessing-officer order covers the payment | No |
| C | Taxable remittance above ₹5 lakh without such a certificate | Form 146 (ex-15CB) |
| D | Remittance not chargeable to tax (specified list) | No |
Remittances completed by 31 March 2026 stay on 15CA/15CB. Lists that label Form 146 as the "tax audit report" are wrong — the audit report is Form 26.
Form 128 — lower or nil deduction
- Section 395(1)/(3), Rule 213; filed on TRACES by the payee (e.g. an NRI selling property, a foreign vendor with treaty relief, a loss-making contractor)
- Attach computation, prior returns, agreement and the payer's TAN or (for individual/HUF property buyers from 1 October 2026) PAN route under s.397(1)(c)
- Valid for the tax year; apply early — the disposal window under Rule 213 is confirmed at filing (the earlier rule allowed 30 days from the month-end of application)
- The Finance Act 2026 adds a s.395(6) route to a prescribed authority
What we do
- Form 146 certification with DTAA/TRC/Form 10F analysis; Form 145 filing and AD-bank documentation
- Form 128 applications before the deed or invoice — see NRI property sale for the worked example
- Repatriation of NRO funds (USD 1 million a year) with the bank; TDS statements (Form 144, ex-27Q) for the payer
Section and form numbers are quoted from the Income-tax Act, 2025, the Income-tax Rules, 2026 and CBDT's form FAQs; anything not yet confirmed on an official page is marked and checked at filing, never estimated.
Talk to us before you file anything
Frequently asked questions
What replaced Form 15CA and 15CB?
Form 145 (ex-15CA) and Form 146 (ex-15CB) under Section 397(3)(d) and Rule 220 of the Income-tax Rules 2026, for remittances on or after 1 April 2026.
When is a CA certificate needed?
For a taxable remittance above ₹5 lakh in the tax year with no Form 128 certificate or officer's order — Part C of Form 145 with Form 146.
Is Form 145 needed for an NRI's property sale proceeds?
Yes, when the proceeds are remitted abroad from the NRO account — typically Part C with Form 146, unless a Form 128 certificate makes it Part B.
What is Form 128?
The lower or nil deduction certificate application (ex-Form 13) under Section 395, filed on TRACES by the payee.
How long does Form 128 take?
It depends on the jurisdictional officer; the earlier rule allowed 30 days from the end of the month of application — apply before the transaction, not after.
How long is a Form 128 certificate valid?
For the tax year in which it is issued, for the specified payer and amount.
Can Part D be used for gifts or maintenance?
Only where the remittance falls in the specified not-chargeable list; otherwise Part A or C applies.
Is a CA mandatory for every remittance?
No — only for Part C cases; Parts A, B and D are filed by the remitter without a certificate.