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Every Section 195 foreign remittance requires Form 15CA online declaration before the AD bank processes the wire, and Form 15CB CA certificate for remittances above ₹5 lakh per purpose code or where a DTAA benefit is claimed. Across a year with dozens of remittances, mismatches between 15CA records, TDS challans, AD bank logs, and Form 27Q entries are common and expose the remitter to Section 276B prosecution and Section 201 interest.
Link every outward remittance to a unique 15CA acknowledgment, a 15CB CA certificate (where above threshold), a TDS challan at the rate certified, and a Form 27Q entry. Enforce one 15CA per remittance, match the AD bank's processed amount and date to the 15CA record, and reconcile the challan rate and amount against the 15CB determination before quarter close.
Remittance register with 15CA acknowledgment, 15CB reference, challan ID, and 27Q quarter fields per payment. One-to-one remittance-to-15CA rule. Threshold logic routing above-₹5-lakh remittances to 15CB.
Every foreign remittance backed by matching 15CA, 15CB, challan, AD bank record, and Form 27Q entry, zero Section 276B exposure, and an auditor-ready reconciliation file for the full year.
Form 15CA 15CB TDS foreign remittance India requirements apply to every Indian company that makes payments outside India that are chargeable to tax. Section 195 governs TDS on such payments, and the Rule 37BB framework requires Form 15CA to be filed online before the remittance is processed by an authorised dealer bank. Where the remittance exceeds prescribed thresholds or a treaty benefit is claimed, Form 15CB — a CA certificate — must precede the 15CA filing. Across a financial year with dozens of foreign remittances, the reconciliation of 15CA filings against underlying payments, TDS challans, and Form 27Q entries is a distinct compliance task.
What Section 195 and the 15CA/15CB Framework Covers
Section 195 requires an Indian payer to deduct TDS on any payment to a non-resident that is chargeable to tax in India — professional fees, royalties, technical services fees, software subscriptions classified as royalty, dividends to NRIs or foreign companies, and interest on borrowings, among others. The standard withholding rate is 20% for most income types unless a DTAA provides a lower rate.
Form 15CA is an online declaration by the remitter, submitted on the income tax portal before the remittance is made. It comes in four parts: Part A for remittances below ₹5 lakh in aggregate in a financial year that are taxable; Part B for remittances exceeding ₹5 lakh where an order under Section 195(2) or 195(3) has been obtained; Part C for remittances exceeding ₹5 lakh where Form 15CB is obtained; and Part D for remittances that are not chargeable to tax.
Form 15CB is the CA certificate that must accompany Part C filings. The certifying CA assesses the nature of income, verifies DTAA applicability, confirms the TDS rate, and signs off that the TDS amount is correct. The 15CB acknowledgement is uploaded to the portal, and its reference number is embedded in the 15CA Part C filing.
Where Reconciliation Breaks Down
15CA filings without matching TDS challans. Companies that file Form 15CA diligently but track TDS deposit separately — often through a different team — discover at year-end that some 15CA remittances have no matching TDS challan, or that the challan amount does not match the TDS stated in the 15CB. The Form 27Q filing then carries a mismatch between the remittance amount, the 15CA reference, and the challan.
DTAA rate applied in 15CB but wrong rate deposited in challan. Where a treaty rate of 10% was applied in the 15CB but TDS was deposited at the standard 20% rate, the excess can be claimed as a refund by the foreign payee — but the Form 27Q entry and the challan must be consistent. If they are not, the 27Q filing is incorrect and a correction return is required.
AD bank records not matching 15CA records. The authorised dealer bank logs the 15CA acknowledgement number for each remittance processed. At year-end, the bank statement shows the actual remittance date and amount. Where multiple remittances were processed under a single 15CA (which is not permitted — each remittance requires a separate 15CA), or where a remittance amount differed from the 15CA amount, the bank’s records will not reconcile to the 15CA register.
Reconciliation Process
Step 1: Build a 15CA register for the year. Export all 15CA acknowledgements from the income tax portal for the financial year. Capture: acknowledgement number, date of filing, part (A/B/C/D), remittance amount, currency, nature of remittance, payee name, country, section, TDS amount, and 15CB reference (where applicable).
Step 2: Match each 15CA to the underlying payment. Cross-reference each 15CA entry against the bank statement or SWIFT record for the remittance. Confirm that the remittance date and amount match. Flag any 15CA with no corresponding bank remittance (filed but remittance not executed) or any bank remittance with no 15CA (compliance gap).
Step 3: Match TDS challans to 15CA-linked payments. For each taxable remittance, confirm that TDS was deposited under the correct challan before the remittance date. The challan must be under Section 195 and the amount must match the TDS stated in the 15CB or the 15CA computation.
Step 4: Reconcile against Form 27Q filing. In the quarterly 27Q return, each deductee entry should carry the 15CA acknowledgement number, the challan reference, the remittance amount, and the TDS deducted. Confirm that all 15CA entries for the quarter are reflected in the corresponding 27Q filing.
Step 5: Address mismatches through correction returns. Where a 15CA acknowledgement number is missing from 27Q, or where the TDS amount in 27Q differs from the challan, file a correction statement for the relevant quarter.
Form 15CA/15CB — Part Selection Guide
| Scenario | 15CA part | 15CB required? | TDS form | Rate |
|---|---|---|---|---|
| Remittance fully exempt (repatriation of capital, listed securities sale) | Part D | No | Not applicable | Nil |
| Taxable remittance below ₹5 lakh aggregate in year | Part A | No | Form 27Q | As per Section 195 / DTAA |
| Taxable remittance above ₹5 lakh — standard rate | Part C | Yes | Form 27Q | As per Section 195 |
| Taxable remittance above ₹5 lakh — treaty benefit claimed | Part C | Yes | Form 27Q | DTAA rate (typically 10–15%) |
| Section 195(2) or 195(3) order obtained from AO | Part B | No | Form 27Q | As per order |
What Automated Reconciliation Changes
Companies that manage foreign remittances through shared folders of PDF certificates frequently discover at year-end that some 15CA filings have no matching challans, or that the TDS deposited under Section 195 does not match the 15CB certificate amount. The correction window — filing a revised 27Q and depositing any shortfall with interest — is available but compresses under year-end audit timelines.
TDS reconciliation software India that maintains a linked register of 15CA acknowledgements, TDS challans, AD bank records, and 27Q entries flags missing links in real time, before the quarter’s return is filed. Reconciliation software India configured for Section 195 remittance tracking gives finance teams a single view of every foreign payment’s compliance status, from 15CA filing through challan deposit to 27Q confirmation.