Form 15CA/15CB for Import Payments in 2026: When Form 145 Is Not Required

Direct answer

For remittances made on or after 1 April 2026, the old Forms 15CA and 15CB have been replaced by Form 145 and Form 146 under the Income-tax Act, 2025 and Income-tax Rules, 2026. For a pure import payment that is not chargeable to tax in India, Form 145 is generally not required where the remittance falls within the import purpose codes specifically listed in Rule 220(3)(c), including S0101 (advance payment against imports) and S0102 (settlement of an import invoice). The exemption is from the information-filing requirement; it is not a substitute for checking whether any part of the payment is actually taxable in India.

Why this question changed from 1 April 2026

Businesses still search for “Form 15CA/15CB for import payments” because those were the familiar compliance forms under section 195(6) of the Income-tax Act, 1961. The Income Tax Department’s transition guidance confirms that remittances made on or after 1 April 2026 follow the Income-tax Act, 2025 and use Form 145 and Form 146. Forms 15CA/15CB filed for remittances completed on or before 31 March 2026 remain part of the old-law workflow.

That makes the date of remittance important. A liability may have arisen before 1 April 2026, but if the actual remittance is made on or after that date, the procedural reporting format follows the 2025 Act. The taxability of the underlying income, however, may still depend on the law applicable to the period in which the income accrued.

Rule 220: the basic Form 145 framework

Rule 220 divides foreign remittances into chargeable and non-chargeable payments. If a sum is chargeable to tax, Part A, B or C of Form 145 applies depending on the aggregate amount and whether an Assessing Officer certificate/order or accountant’s certificate has been obtained. If the payment is not chargeable, Part D ordinarily applies—unless the payment is covered by one of the express exemptions in Rule 220(3).

For taxable remittances, the ₹5 lakh threshold remains central. Part A applies where the taxable payment or aggregate of taxable payments during the tax year does not exceed ₹5 lakh. Above ₹5 lakh, Part B applies where the relevant Assessing Officer certificate/order is available; otherwise Part C is used after obtaining Form 146 from an accountant.

Import payments specifically exempted under Rule 220(3)(c)

Rule 220(3)(c) provides that no Form 145 information is required for a non-chargeable remittance falling within the specified RBI purpose-code list. Import-related entries in that list include:

• S0101 — Advance payment against imports. • S0102 — Payment towards import (settlement of invoice). • S0103 — Imports by diplomatic missions. • S0104 — Intermediary trade. • S0190 — Imports below ₹5,00,000 (for use by Exchange Control Department offices). • S0602 — Freight insurance relating to import and export of goods is also separately included in the specified list.

The practical point is that the purpose-code exemption operates for a sum that is not chargeable under the Act. A payment does not become non-taxable merely because the bank labels it as an import payment.

When an import invoice can still create tax and Form 145/146 issues

A straightforward purchase of goods from a foreign supplier, with no India-source income embedded in the consideration, is different from a composite cross-border contract. Problems arise when an invoice combines goods with technical services, software rights, royalty, installation, commissioning, design, supervision, warranty support or other service elements. In such cases, the tax team should not rely only on the import purpose code.

The correct approach is to identify the legal character of each payment stream, test chargeability under the Income-tax Act, 2025 or the relevant transition law, review the applicable DTAA where relevant, and then determine whether Form 145, Form 146 and TDS are required. A mixed invoice may need to be split rather than treated as a single exempt import remittance.

Example: pure goods import vs mixed contract

Example 1 — An Indian manufacturer remits ₹30 lakh to an unrelated overseas vendor solely for imported machinery under a normal purchase contract. There is no separate royalty, service fee or other taxable India-source component. If the remittance is not chargeable to tax and is correctly classified under S0102, Rule 220(3)(c) can remove the Form 145 information-filing requirement even though the payment exceeds ₹5 lakh.

Example 2 — The same ₹30 lakh invoice includes ₹5 lakh for on-site technical installation in India. The entire invoice should not automatically be treated as an exempt S0102 import payment. The technical-service component requires a separate chargeability and treaty analysis. Depending on the conclusion, TDS and Form 145/146 compliance may arise for that component.

The ₹5 lakh threshold is often misunderstood

The ₹5 lakh threshold is not a blanket exemption for foreign remittances. It determines which part of Form 145 applies when a payment is chargeable to tax. By contrast, Rule 220(3) can remove the Form 145 information requirement for specified non-chargeable remittances, including listed import purpose codes. These are two different tests and should not be mixed.

What finance teams should document before the bank remittance

A defensible import-remittance file should normally contain: the purchase order and contract; commercial invoice; bill of entry or import evidence where available; RBI purpose code; vendor tax-residency details where relevant; a short taxability note; confirmation on whether the invoice contains services, royalty or other rights; TDS analysis; and the Form 145/Form 146 conclusion. Where the payment is treated as exempt under Rule 220(3)(c), the file should record the exact purpose code and why the sum is considered non-chargeable.

Banks may also request documents under FEMA, trade and internal compliance procedures even where Form 145 is not required. The income-tax reporting exemption should therefore not be read as an exemption from the authorised dealer’s separate documentation requirements.

Practical checklist for import remittances in 2026

1. Confirm the actual date of remittance: before or after 1 April 2026. 2. Identify whether the payment is purely for goods or includes services/rights. 3. Test whether any amount is chargeable to tax in India. 4. Confirm the RBI purpose code used by the authorised dealer. 5. If non-chargeable, check whether Rule 220(3)(c) specifically covers that purpose code. 6. If chargeable, determine whether Form 145 Part A, B or C applies. 7. Obtain Form 146 before Part C where required. 8. Reconcile the tax conclusion with TDS, treaty documents and the underlying contract. 9. Retain the working paper and bank documentation with the remittance file.

Frequently asked questions

Is Form 15CA required for import of goods after 1 April 2026?

No. For remittances made on or after 1 April 2026, Form 145 replaces Form 15CA. For a non-chargeable import payment falling within a specified Rule 220(3)(c) purpose code such as S0101 or S0102, Form 145 information is generally not required.

Is Form 146 required merely because the import payment exceeds ₹5 lakh?

No. The ₹5 lakh threshold matters in the taxable-remittance framework. A pure import payment that is not chargeable and is covered by Rule 220(3)(c) does not become subject to Form 146 merely because its value exceeds ₹5 lakh.

Can a bank still ask for a CA certificate?

An authorised dealer may seek supporting documents under its FEMA, trade or internal risk procedures. That operational request is different from the statutory Form 146 requirement under the Income-tax Rules, 2026.

What if the invoice includes software, royalty or installation charges?

Do not treat the whole invoice as an exempt goods-import payment without analysis. Identify and test the service or rights component separately for taxability, TDS and Form 145/146 consequences.

Related PGT & Associates guides

Form 15CA/15CB Is Now Forms 145/146: https://www.pgtandassociates.com/post/form-15ca-15cb-is-now-forms-145-146-the-2026-foreign-remittance-compliance-redesign When Is Form 145 Not Required?: https://www.pgtandassociates.com/post/form-145-not-required When Is Form 146 Required?: https://www.pgtandassociates.com/post/form-146-foreign-remittance

Primary sources

Income-tax Rules, 2026 — Rule 220 and Forms 145/146: https://www.incometax.gov.in/iec/foportal/sites/default/files/2026-03/En-Notified-IT-Rules-2026-20-03-2026.pdf Income Tax Department — Form 145 user manual: https://www.incometax.gov.in/iec/foportal/newformpage/forms/form145-UM Income Tax Department — transition FAQs for Forms 15CA/15CB and Forms 145/146: https://www.incometax.gov.in/iec/foportal/help/all-topics/e-filing-services/income-tax-forms

How PGT & Associates can help

Cross-border remittances frequently sit at the intersection of income tax, treaty analysis, FEMA and bank documentation. PGT & Associates can assist businesses with remittance taxability reviews, Form 145/146 conclusions, TDS analysis and documentation for authorised-dealer queries. For professional assistance, visit https://www.pgtandassociates.com/contact-us.

Disclaimer: This article is for general professional information and does not constitute legal, tax or investment advice. The taxability of a cross-border payment depends on the contract, facts, applicable treaty, place and period of accrual, and the law in force for the relevant transaction. Obtain transaction-specific advice before remitting funds.