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A finance analyst at an Indian mid-market services firm receives an invoice for Rs 12 lakh from a US-based analytics consulting firm for a technical services engagement. The authorised dealer bank has told the remitter it will not action the outward wire until Form 15CA (and, if required, Form 15CB) is on file. The remitter has heard of both forms but is not sure which one is the self-declaration and which one is the CA's certificate, whether the aggregate remittance already made to non-residents this financial year matters, and which of the four Parts of Form 15CA the Rs 12 lakh payment falls into. The wire is time-sensitive and the bank has an internal deadline for the day's SWIFT batch. The question is not whether to file — the filing is mandatory before the bank will release the wire. The question is which Part applies, whether a Form 15CB from a CA is needed, and how the filing feeds the TDS return under Section 195 (or Section 393(2) from April 2026).
Form 15CA is the remitter's self-declaration to the bank, filed online on incometax.gov.in in one of four Parts. Form 15CB is a chartered accountant's certificate that examines the transaction's taxability, DTAA benefit, and TDS rate under Section 195, and is required only when Part C of Form 15CA is triggered. The Part is determined by two tests read together — the aggregate FY remittance threshold (Rs 5 lakh) and the chargeability of the remittance to tax under the Act. Part A applies where the aggregate is Rs 5 lakh or less, whether taxable or not. Part B applies where the remittance is taxable but the deductor has obtained a Section 197 lower-deduction certificate or a Section 195(2)/195(3) order from the AO. Part C applies where the aggregate exceeds Rs 5 lakh, the remittance is taxable, and no AO document is in play — Form 15CB is mandatory here. Part D applies where the remittance is not chargeable to tax under the Act or falls within the 33 exempted transactions under Rule 37BB. On the illustrative Rs 12 lakh consultant fee, the aggregate FY remittance has crossed Rs 5 lakh (the remitter had earlier paid Rs 4 lakh to a UK software vendor and Rs 2 lakh to a Singapore agency in the same FY), the payment is chargeable to tax under Section 195 as fees for technical services, and no AO certificate is in play. Part C applies and Form 15CB is mandatory before Form 15CA can be filed.
Access to incometax.gov.in with the remitter's PAN credentials. An empanelled chartered accountant with active membership and no debarment, for Form 15CB certification (Part C only). The DTAA text for the remittee's country of tax residence (for example the India-US DTAA for a US consultant, the India-Singapore DTAA for a Singapore agency, the India-UK DTAA for a UK vendor). A Tax Residency Certificate (TRC) from the remittee's home tax authority and Form 10F from the remittee, both required for the DTAA benefit under Section 90(4). A No PE (permanent establishment in India) declaration from the remittee, required for the DTAA business-profits article to apply. A running FY register that captures every outward remittance to any non-resident with date, amount, purpose code, and Part filed — the register is what tests the Rs 5 lakh aggregate threshold in real time and prevents a Part A filing that should have been Part C. A calendar tracking the Form 15CB validity window (a fresh 15CB per remittance; no rolling 15CB) and the bank's SWIFT cut-off for the day.
Every outward remittance to a non-resident is classified into the correct Part of Form 15CA at the point of remittance, with Form 15CB obtained from the empanelled CA where Part C is triggered. The Form 15CA acknowledgement number is provided to the authorised dealer bank with the remittance instruction, the bank verifies the acknowledgement on incometax.gov.in, and the wire is released within the day's SWIFT batch. The corresponding TDS deduction under Section 195 (or Section 393(2) code 1057 from 1 April 2026) is deposited on time, the Section 195 deduction leg flows into Form 26Q for the quarter, and the deductee's Form 26AS and Form 168 reflect the credit within three to seven business days of the return processing. The FY aggregate register carries a defensible record of every Part A, Part B, Part C, and Part D filing for the year, and the authorised dealer bank's inspection sample and any subsequent AO scrutiny under Section 195 draw on the same running record.
The invoice on your desk is Rs 12 lakh, from a US-based analytics consulting firm. Your bank has said it will not action the outward wire until Form 15CA is on file. Someone on the tax desk has mentioned Form 15CB and a chartered accountant’s certificate. The two names sound almost the same. Are they the same form under two names? Different forms? Which one do you file yourself, and which one needs the CA to sign?
The wire is time-sensitive. The bank has a SWIFT batch cut-off at four in the afternoon. And no one wants to spend the day chasing a form that turns out to be optional.
The quick answer
Form 15CA is the remitter’s own online self-declaration to the bank, filed on incometax.gov.in in one of four Parts (A, B, C, or D). Form 15CB is a separate certificate signed by a chartered accountant that examines the taxability of the remittance, the DTAA benefit, and the correct TDS rate under Section 195. The two are different forms with different signers and different scopes — the remitter files Form 15CA; a CA signs Form 15CB.
Form 15CB is required only when Part C of Form 15CA is triggered, which is roughly one remittance in four for a typical mid-market remitter. Part C applies where the aggregate of all remittances to any non-resident during the financial year exceeds Rs 5 lakh, the payment is chargeable to tax under the Act, and no lower-deduction certificate or Section 195(2)/195(3) order from the Assessing Officer is in play. The Rs 12 lakh consultant fee on your desk, assuming the FY-aggregate threshold has already been crossed and no AO certificate exists, falls squarely into Part C — Form 15CB is mandatory before Form 15CA can be filed.
Form 15CA — the remitter’s self-declaration to the bank
Form 15CA is filed online by the remitter on the Income Tax Department e-filing portal using the remitter’s PAN credentials. It carries the remitter’s details, the remittee’s details (name, country of tax residence, address), the amount, the purpose code from the RBI purpose code list (for example P1006 for consultancy services, P0801 for freight), and the Part under which it is being filed. The portal generates an acknowledgement number on successful filing — this is the number the authorised dealer bank verifies before releasing the wire.
The parent rule is Rule 37BB of the Income-tax Rules 1962, which is the source of the four-part logic and the Rs 5 lakh aggregate threshold. The four-part structure itself was notified in December 2015 (CBDT Notification 93/2015) with effect from 1 April 2016, replacing the earlier undivided form. The revision was intended to reduce the compliance burden on small-value and non-taxable remittances — a Rs 40,000 personal remittance for family maintenance abroad now files under Part D (or is exempted entirely), and a taxable Rs 3 lakh remittance to a first-year overseas vendor files a simple Part A. Only Part C carries the Form 15CB obligation.
Form 15CB — the CA’s certificate of taxability
Form 15CB is issued by an empanelled chartered accountant after examining three things — whether the sum is chargeable to tax in India under the Income-tax Act, whether a DTAA (Double Taxation Avoidance Agreement) benefit reduces the domestic rate, and what the correct TDS rate on the remittance is. The certificate is a signed document uploaded to incometax.gov.in by the CA under their own membership credentials, and the resulting Form 15CB certificate number is what the remitter references when filing Part C of Form 15CA.
The Form 15CB is a Section 195 professional certification. The bank cannot verify Section 195 compliance on its own — the Section 195 obligation on payments to non-residents requires the deductor to withhold tax at the rates in force at the time of credit or payment (whichever is earlier), and the rate depends on the nature of the payment, the DTAA article that applies, and the availability of a Tax Residency Certificate (TRC) and Form 10F. The Form 15CB is the CA’s professional take on all of that, and it is the document the authorised dealer bank relies on before releasing the wire — and the document the Assessing Officer relies on if the deduction is later challenged.
The TRC and when it is required walkthrough is the deeper treatment of the DTAA-benefit prerequisite that feeds into every Form 15CB analysis.
The four Parts of Form 15CA
Part A — aggregate up to Rs 5 lakh in the FY
Applies to a single remittance or an aggregate of remittances up to Rs 5 lakh in the financial year, whether the remittance is chargeable to tax or not. No Form 15CB, minimal information required, quick to file.
Illustrative case — a Rs 3 lakh consultancy fee to a Sri Lankan design firm, filed in June, first foreign remittance of the financial year. Part A. No CA certificate.
Part B — taxable, but a Section 197 or Section 195(2)/195(3) document is in play
Applies where the remittance is taxable but the deductor has obtained a Section 197 lower-deduction certificate or a Section 195(2) or Section 195(3) order from the Assessing Officer. The AO’s certificate or order replaces the Form 15CB — the AO has already ruled on the taxability and rate, and the CA’s re-certification is not needed.
Illustrative case — a Rs 45 lakh royalty payment to a foreign parent where the deductor has obtained a Section 195(2) order from the AO fixing the withholding rate at 10 per cent under the treaty. Part B. The AO order is attached; no Form 15CB.
Part C — aggregate exceeds Rs 5 lakh in the FY, taxable, no AO document
Applies where the aggregate for the financial year exceeds Rs 5 lakh, the remittance is chargeable to tax under the Act, and no AO certificate or order is in play. Form 15CB from a chartered accountant is mandatory before Form 15CA can be filed.
Illustrative case — the Rs 12 lakh technical services fee to the US analytics firm on your desk. The remitter had earlier remitted Rs 4 lakh to a UK software vendor in May and Rs 2 lakh to a Singapore agency in July of the same FY — the aggregate has already crossed the Rs 5 lakh threshold. The Rs 12 lakh payment is chargeable to tax under Section 195 as fees for technical services. No AO certificate. Part C. Form 15CB mandatory.
Part D — not chargeable to tax under the Act, or exempted transaction
Applies where the remittance is either not chargeable to tax under the Act (for example a trade payment covered by the DTAA business-profits article where the non-resident has no permanent establishment in India) or falls within the 33 exempted transactions notified under Rule 37BB.
Illustrative case — a Rs 18 lakh commission to an overseas agent for export services rendered wholly outside India, where the DTAA business-profits article and the No PE declaration together take the payment out of the Section 195 net. Part D. No Form 15CB, minimal information required.
The 33 exempted transactions — where no Form 15CA is needed at all
Not every outward remittance triggers a Form 15CA. Rule 37BB carries a list of 33 transactions that are exempted from the Form 15CA requirement entirely — the bank does not require the form, and no filing is done on incometax.gov.in. The list includes personal remittances (family maintenance abroad, gifts, donations), specific trade payments (imports of goods, imports of raw materials — already covered by the customs and GST record), and a set of Government-related transfers.
Before filing any Form 15CA — Part A included — verify the purpose against the exempted list. A Part A filed for an exempted transaction is a compliance overhead the remitter did not need. The purpose codes on the RBI list line up against the Rule 37BB exempted-transaction list, and the bank’s remittance form asks for the purpose code first for exactly this classification reason.
The illustrative Rs 12 lakh — end-to-end walkthrough
Working the Rs 12 lakh consultant fee end-to-end.
Test 1 — is it an exempted transaction? The purpose code is P1006 (consultancy services). Not on the Rule 37BB exempted list. Form 15CA is required.
Test 2 — what is the aggregate FY remittance so far? The FY register shows Rs 4 lakh in May and Rs 2 lakh in July — Rs 6 lakh already. The Rs 12 lakh will take the aggregate to Rs 18 lakh. Above the Rs 5 lakh threshold.
Test 3 — is the payment chargeable to tax in India? Fees for technical services to a non-resident are chargeable under Section 9(1)(vii) read with Section 195, subject to any lower rate under the India-US DTAA (Article 12 — Royalties and Fees for Included Services). Yes, chargeable — the DTAA reduces the rate, it does not remove chargeability.
Test 4 — is there a Section 197 certificate or Section 195(2)/195(3) order? No.
The four tests together point at Part C. Form 15CB from the empanelled CA is filed first (the CA examines the DTAA benefit, verifies the TRC and Form 10F from the US remittee, confirms the No PE declaration, and certifies the rate). The Form 15CB certificate number is generated on incometax.gov.in. The remitter then files Form 15CA Part C on incometax.gov.in, referencing the Form 15CB number. The Form 15CA acknowledgement number is provided to the bank with the remittance instruction. The bank verifies the acknowledgement, releases the wire, and the corresponding TDS under Section 195 is deposited on the seventh of the following month.
From 1 April 2026, the underlying Section 195 anchor migrates to Section 393(2) Serial No. 17 with payment code 1057 for a residual non-resident payment. The Form 15CA and Form 15CB workflow itself is unchanged in substance; the code metadata that flows to Form 26Q from Q1 FY 2026-27 is what changes. The Section 393 payment code finder tool narrows a specific remittance to the exact successor code, and the TDS payment codes 1001 to 1092 reference is the full cross-era coding table.
The one to escalate first — the wrong Part
The classification the bank will bounce back is Part A filed where Part C was needed. The remitter looks only at the single-remittance value (Rs 3 lakh, Rs 4 lakh, or similar) and files Part A because the individual number is under Rs 5 lakh — missing that the Rs 5 lakh test is the aggregate for the financial year across every non-resident remittance, not the single-payment value. The bank verifies the acknowledgement on the portal and finds Part A filed for a remittance that pushes the FY aggregate past Rs 5 lakh. The file bounces back and the SWIFT batch misses the cut-off.
The fix is a running FY register — one row per outward remittance with date, amount, purpose code, and Part filed — refreshed at the moment of filing. Before filing any Form 15CA, run the register sum. If the year-to-date total plus the current remittance exceeds Rs 5 lakh, the current remittance is Part C (assuming taxable and no AO document), regardless of its individual value. The Only Representative retainer and foreign vendor Section 195 reconciliation walk in the chemicals cluster covers the same aggregate-test discipline in a Section 195 monthly reconciliation setting.
When the manual filing cycle outgrows itself
One or two Form 15CA filings a month is normal residual for a mid-market services firm — a routine tax-executive task alongside the monthly TDS close. The manual workflow (running the FY aggregate, verifying the exempted list, requesting the Form 15CB from the CA where Part C is triggered, filing on incometax.gov.in, forwarding the acknowledgement to the bank) fits inside a few hours per remittance and one tax executive can hold it.
Above eight to ten remittances a month — a services firm with multiple overseas contractors, an e-commerce business with several international payment gateway settlement outflows, or a licensed reinsurance intermediary with a running foreign-cedant remittance program — the FY aggregate discipline stops being a filing task and becomes a live register that has to be refreshed on the day of every remittance. The Form 15CB request queue with the empanelled CA becomes a running turnaround (a fresh Form 15CB per remittance; no rolling 15CB), and the bank’s SWIFT cut-off becomes a hard deadline the tax executive is racing every day. At that scale, moving the FY aggregate register, the Rule 37BB exempted-list verification, and the Section 195 rate-and-DTAA reconciliation onto continuously refreshed detection — where Terra Insight’s TDS reconciliation software treats the outward-remittance register and the Section 195 deposit reconciliation as first-class outputs — keeps the tax executive out of the day-to-day cut-off race and holds the monthly TDS close inside a fifteen-day cadence.
Go deeper
- Form 15CA and Form 15CB in the outward-remittance reconciliation — the technical treatment
- Section 195 TDS on payments to non-residents — the pillar-level treatment
- Tax Residency Certificate — what it is and when you need it
- TDS payment codes 1001 to 1092 — the Section 393(1) cross-era mapping
- NRI property seller — Section 195 versus Section 194-IA
- Only Representative retainer and foreign vendor Section 195 in the chemicals annual reconciliation
- Section 393 payment code finder — narrow a remittance to the correct successor code
Frequently Asked Questions
Do I need Form 15CB for every foreign remittance?
No. Form 15CB is required only when the remittance is chargeable to tax under the Act and the aggregate of remittances to non-residents during the financial year exceeds Rs 5 lakh — the Part C case under Rule 37BB. A single or aggregate remittance up to Rs 5 lakh in the financial year (Part A) does not need a Form 15CB. A taxable remittance that is covered by a Section 197 lower-deduction certificate or a Section 195(2) or 195(3) order from the Assessing Officer (Part B) does not need a Form 15CB either — the AO’s certificate or order replaces the CA’s certification. A remittance that is either not chargeable to tax under the Act or falls within the 33 exempted transactions notified under Rule 37BB (Part D) does not need a Form 15CB. Roughly speaking, only one Form 15CA in four ends up in Part C for a typical mid-market remitter — but that one is the one where the bank will bounce the file back without the CA’s certificate on record.
What is the difference between Part A, Part B, Part C, and Part D of Form 15CA?
Part A — single or aggregate remittances up to Rs 5 lakh in the financial year, whether taxable or not, no Form 15CB, minimal information. Part B — taxable remittances where the deductor has obtained a Section 197 lower-deduction certificate or a Section 195(2) or 195(3) order from the Assessing Officer; the AO’s document replaces the Form 15CB. Part C — taxable remittances where the aggregate for the financial year exceeds Rs 5 lakh, no AO certificate in play, and a Form 15CB from a chartered accountant is mandatory before Form 15CA can be filed. Part D — remittances that are either not chargeable to tax under the Act (for example most trade payments covered by DTAA business-profits article without a permanent establishment in India) or fall within the 33 exempted transactions notified under Rule 37BB. The selection of Part is a legal classification, not a discretionary choice — a Rs 12 lakh taxable consultant fee cannot be filed under Part A on the argument that only Rs 4 lakh has been remitted this quarter; the aggregate FY test looks at every remittance to any non-resident since 1 April.
My remittance is Rs 3 lakh and it is my first foreign remittance this financial year. Do I still need to file anything?
Yes — Part A of Form 15CA. Part A applies to a single remittance or an aggregate of remittances up to Rs 5 lakh in the financial year, whether the remittance is chargeable to tax or not. The information required in Part A is minimal (remitter details, remittee details, amount, purpose code from the RBI purpose code list), no CA certification is needed, and the acknowledgement generated on incometax.gov.in is what the authorised dealer bank verifies before releasing the wire. The one exception is where the remittance falls within the 33 exempted transactions under Rule 37BB — for example a payment towards imports of goods (already covered by the customs and GST record) or a personal remittance for family maintenance abroad — in which case no Form 15CA is required at all. Verify the purpose against the exempted list before filing Part A; a Part A filed unnecessarily is a compliance overhead the remitter did not need.
Can the authorised dealer bank release the wire without Form 15CA?
No, unless the remittance is on the exempted list under Rule 37BB. CBDT Circular 1/2019 requires the authorised dealer bank to obtain a valid Form 15CA (and, where Part C applies, a Form 15CB) before releasing any outward remittance to a non-resident. The bank verifies the Form 15CA acknowledgement number on incometax.gov.in before actioning the SWIFT or wire instruction — a Form 15CA that has been filed but not acknowledged, or filed under the wrong Part (a Part A where Part C was needed), is treated as invalid and the bank returns the remittance file. The bank also retains the Form 15CA and, where applicable, the Form 15CB in its records for the period prescribed under the Foreign Exchange Management Act 1999, and produces the records on demand to the Reserve Bank of India during a routine or targeted inspection. This is why the bank’s classification acceptance is the operational sign-off on the remittance, not the filing itself — a filed but wrongly classified form does not get the wire out the door.
What changes with the Income-tax Act 2025 and Section 393 from 1 April 2026?
The Form 15CA and Form 15CB workflow is unchanged in substance — Rule 37BB is expected to be reissued under the Income-tax Rules 2026 preserving the Parts A, B, C, and D structure and the Rs 5 lakh aggregate threshold. The change is in the metadata that flows to the deductor’s TDS return: the Section 195 obligation migrates to Section 393(2) Serial No. 17, and a residual non-resident payment is reported in Form 26Q from Q1 FY 2026-27 onwards against payment code 1057. A Part C remittance filed in April 2026 needs the Form 15CB narrative to reference the Section 393(2) successor code, and the deductor’s TDS working paper should carry both the legacy Section 195 anchor (for historical audit trail) and the new code 1057 (for the current filing). The Section 393 payment code reference in the article’s Go deeper block walks the full cross-era coding table, and the payment code finder tool linked below narrows a specific remittance to the exact successor code.
Content authored by practitioners with experience at Amazon India, Intuit QuickBooks, and the Tata Group. Meet the team →
- ▸ Rule 37BB, Income-tax Rules 1962 — The person responsible for paying to a non-resident, not being a company, or to a foreign company, any sum, whether or not chargeable to tax under the provisions of the Act, shall furnish the following, namely — the information in Part A of Form 15CA if the amount of payment or the aggregate of such payments does not exceed five lakh rupees during the financial year; the information in Part B of Form 15CA after obtaining a certificate from the Assessing Officer under Section 197 or an order from the Assessing Officer under Section 195(2) or Section 195(3); the information in Part C of Form 15CA after obtaining a certificate in Form 15CB from an accountant, where the payment or the aggregate of such payments during the financial year exceeds five lakh rupees and is chargeable to tax under the Act; and the information in Part D of Form 15CA where the payment is of the nature specified in the list of exempted transactions or is not chargeable to tax under the Act. The parent rule is the source of the four-part logic that governs every outward remittance a resident makes to a non-resident, and it is the rule the authorised dealer bank quotes when it refuses to release the wire without a valid form on record.
- ▸ CBDT Notification 93/2015 dated 16 December 2015 — The four-part structure of Form 15CA — Parts A, B, C, and D — was notified with effect from 1 April 2016, replacing the earlier undivided form. The revision was intended to reduce the compliance burden on small-value and non-taxable remittances, which now file only Part A or Part D and do not require a Form 15CB from a chartered accountant. Only Part C — a taxable remittance whose aggregate for the financial year exceeds five lakh rupees — carries the Form 15CB requirement, and Part B carries a separate documentary anchor (a Section 197 certificate or a Section 195(2) or 195(3) order from the Assessing Officer) instead of a Form 15CB. The notification also expanded the list of exempted transactions from 28 to 33, covering personal remittances (family maintenance abroad, gifts, donations), specific trade payments (imports of goods, imports of raw materials), and a set of Government-related transfers that do not need a Form 15CA or Form 15CB at all.
- ▸ CBDT Circular 1/2019 dated 1 January 2019 — The circular provides operating guidance to authorised dealer banks and remitters on the Form 15CA and Form 15CB workflow. Banks are required to obtain a valid Form 15CA (and, where applicable, a Form 15CB) before releasing any outward remittance to a non-resident, and to retain the forms in their records for the period prescribed under the Foreign Exchange Management Act 1999. The circular clarifies that the Form 15CA acknowledgement number generated on incometax.gov.in is the record the bank verifies before releasing the wire — a Form 15CA filed but not acknowledged, or filed under the wrong Part, is treated as invalid and the bank must return the remittance instruction. A revised Form 15CA can be filed to replace an invalid one, but every revision requires a fresh Form 15CB if Part C is triggered.
- ▸ Section 195, Income-tax Act 1961 — Any person responsible for paying to a non-resident, not being a company, or to a foreign company, any interest or any other sum chargeable under the provisions of this Act shall, at the time of credit of such income to the account of the payee or at the time of payment thereof in cash or by the issue of a cheque or draft or by any other mode, whichever is earlier, deduct income-tax thereon at the rates in force. The Form 15CB requirement in Part C is anchored in the deductor's Section 195 obligation — the CA's certificate confirms whether the sum is chargeable to tax in India, whether a DTAA (Double Taxation Avoidance Agreement) benefit reduces the rate, and what the correct TDS rate on the remittance is. The bank cannot verify Section 195 compliance on its own; the Form 15CB is the professional certification the bank relies on before releasing the wire, and it is the document the Assessing Officer relies on if the deduction is later challenged.
- ▸ Section 393, Income-tax Act 2025 — The Income-tax Act 2025, effective 1 April 2026, consolidates the tax-deduction and tax-collection provisions of the Income-tax Act 1961 into Section 393. The Section 195 obligation on payments to non-residents migrates to Section 393(2) Serial No. 17 with payment code 1057 for a residual non-resident payment. The Form 15CA workflow and the Form 15CB certification requirement are unchanged under the new Act — the four-part structure of Rule 37BB continues, and CBDT is expected to reissue an equivalent rule under the Income-tax Rules 2026 preserving Parts A, B, C, and D. What changes is the payment-code metadata on the corresponding TDS return: a Part C remittance in FY 2026-27 is reported in Form 26Q against code 1057 instead of Section 195, and the Form 15CB narrative should reflect the successor code.