Form 145 and Form 146 when the payer is a company

Form 145 (formerly Form 15CA) is the remitter's declaration under Rule 220. Form 146 (formerly Form 15CB) is the accountant's certificate. The Form 145 note sets the parts out as follows.

Part C is the one that needs the chartered accountant. The note says upload of Form 146 is mandatory before Part C, and the acknowledgement number of the e-filed Form 146 is what prefills Part C.

Form 146 is required when the payment is taxable, the year's aggregate exceeds ₹5 lakh, and you do not have a certificate under section 395(1) or 395(2). The accountant examines chargeability under sections 5 and 9 and under the treaty, if one is claimed.

The Form 145 note lists three payments that are outside the form: a remittance by an individual that does not need prior RBI approval, a remittance by a unit of an International Financial Services Centre, and a remittance of a nature specified under the relevant RBI purpose code. A company does not fall into the first of those. Check the purpose code against Rule 220 rather than assuming an import or a software subscription is on the list.

Through 31 March 2026 the same structure was Rule 37BB, Form 15CA and Form 15CB.

The company adds the chartered accountant on the e-filing portal (My Account, Add CA, Form 146). The accountant, registered as a chartered accountant and holding a digital signature, files Form 146. The verification block asks for the accountant's name, PAN, membership number, firm name, firm registration number and UDIN. The note says UDIN is mandatory for Form 146 under the ICAI notification, and the portal also lets the accountant proceed and update UDIN later.

The company then files Form 145. For a TAN login, DSC is mandatory. After e-verification the portal issues a transaction id and an acknowledgement number.

The note says a copy of the form and the acknowledgement goes to the authorised dealer before the remittance is processed. It also describes a change to Rule 220 so Form 145 can be delivered to the authorised dealer electronically, which is meant to remove the printed copy. Give the bank the acknowledgement it asks for. Form 146 can be withdrawn within 7 days of submission, and so can Form 145. Once a Form 145 Part C is filed against a Form 146, that Form 146 is marked consumed, and one certificate covers one Form 145.

Part C of Form 145 asks for the UDIN. Part C no longer asks for the Assessing Officer certificate details: if you have that certificate you file Part B, not Part C.

If a person fails to submit Form 145, or submits inaccurate information, the Form 145 note says the penalty is up to ₹1 lakh under section 462. The note's header lists section 271-I of the 1961 Act among the old sections for this form.

If an accountant furnishes inaccurate information in Form 146, the Form 146 note says the penalty is up to ₹10,000 for each such certificate under section 463. The note's header lists section 271J of the 1961 Act as the old counterpart for the certificate.

The department's Form 145 note describes mismatches with the authorised dealer's quarterly statement in Form 147: clerical re-keying, the exchange rate moving between the Form 145 date and the remittance date, the dealer capturing the same Form 145 twice, and more than one Form 145 filed to correct a single payment. Those are the operational points the note itself names.