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The Income-tax Act 2025: what changed for NRIs (old vs new forms and sections)

From 1 April 2026, India runs on a new Income-tax Act. The residence test is the same, but most of the forms and section numbers you know were renumbered. Here is the plain old-to-new map, what genuinely changed, and why your FY 2025-26 filing still uses the old forms.

Last reviewed: 21 June 20268 min readBy Vipul Sharma, Founder · reviewed by Preetesh Maloo, CA

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Statutory references on this page

  • Income-tax Act, 2025 (Act 30 of 2025) — in force 1 April 2026, repealing the Income-tax Act, 1961
  • Income-tax Rules, 2026 — CBDT Notification 22/2026, G.S.R. 198(E), 20 March 2026
  • Section 159(8) + Rule 75 — Form 41 (DTAA self-declaration, formerly Form 10F)
  • Section 395 — certificate for lower or nil TDS (Form 128, formerly Form 13 under Section 197)
  • Section 393 — TDS on payments to non-residents (formerly Section 195)
  • Section 536 — repeal and savings (old circulars, TRCs and certificates stay valid)

Is the Income-tax Act 2025 actually in force?

Yes. It received the President's assent on 21 August 2025 (Act 30 of 2025) and came into force on 1 April 2026, replacing the Income-tax Act, 1961. The forms you actually file are set by the Income-tax Rules, 2026, which CBDT notified on 20 March 2026 (Notification 22/2026). So the new form and section numbers are live law, not a proposal.

The catch most NRIs miss: the new Act applies to income earned from 1 April 2026 onward — the new "Tax Year 2026-27". Your income for FY 2025-26 is still taxed under the old 1961 Act, on the old forms, even though you file that return after April 2026. The return you file in July 2026 is an old-Act return. A savings clause (Section 536) keeps old circulars, certificates and Tax Residency Certificates valid through the changeover.

In one line: old forms for old years, new forms from Tax Year 2026-27.

The forms NRIs use — old to new

Most NRI paperwork was renumbered when the Income-tax Rules, 2026 took over. The form does the same job; only the number changed. These are the ones worth knowing:

Old form (until FY 2025-26)New form (from 1 Apr 2026)What it does
Form 10FForm 41Self-declaration a non-resident files (with the TRC) to claim a DTAA rate — Rule 75 / Section 159(8)
Form 15CAForm 145Remitter's declaration for a foreign remittance out of India
Form 15CBForm 146Chartered Accountant's certificate for a taxable foreign remittance (over ₹5 lakh)
Form 13Form 128Application for a certificate for lower or nil TDS — now under Section 395 (was Section 197)
Form 49AForm 93PAN application — individuals who are citizens of India (incl. NRIs on an Indian passport)
Form 49AAForm 95PAN application — individuals who are NOT citizens of India (OCI / foreign passport); Form 96 is for a foreign entity
Form 27QForm 144TDS return the buyer files on a payment to a non-resident (e.g. buying property from an NRI)
Form 16AForm 131TDS certificate (non-salary) — what the buyer/payer issues to the NRI for tax withheld
Form 26ASForm 168Your annual tax statement (TDS credited against your PAN) — renumbered, not abolished
Form 67Form 44Foreign Tax Credit statement — now needs a CA certificate where foreign tax is ₹1 lakh or more
Form 10EEForm 40Election for Section 158 (was Section 89A) relief on a foreign retirement account

Two things to flag, because the popular blogs get them wrong. First, the PAN forms split: the old Form 49A (Indian citizens) is now Form 93, and the old Form 49AA (foreign citizens) became Form 95 for an individual and Form 96 for an entity — so an OCI applying for a PAN uses Form 95, not 96. Second, several online mapping tables list 15CA as "131" and 27Q as "140"; both are wrong. The correct successors are Form 145 and Form 144, confirmed on the income-tax department's own form pages.

The sections NRIs run into — old to new

The Act renumbered most sections, but not all. Residence (Section 6) and the "income deemed to arise in India" rule (Section 9) kept their numbers, which is why you will still see them quoted the same way.

Old section (1961 Act)New section (2025 Act)What it covers
Section 6Section 6Residential status (the day-count test) — number unchanged
Section 9Section 9Income deemed to accrue or arise in India — number unchanged
Section 90 / 90ASection 159DTAA / treaty relief — now expressly needs a TRC + Form 41 to claim (Section 159(8))
Section 195Section 393(2)TDS on payments to a non-resident — substance and rates unchanged
Section 197Section 395Certificate for lower / nil TDS (Form 128). ⚠ The NEW Section 197 is now long-term capital gains
Section 54 / 54EC / 54FSection 82 / 85 / 86Capital-gains exemptions on a property sale (reinvest in a house / 54EC bonds)
Section 111A / 112 / 112ASection 196 / 197 / 198Capital-gains tax rates (STCG, LTCG non-equity, LTCG equity)
Section 89ASection 158Relief on a foreign retirement account (Form 10EE → Form 40)

Watch one trap. The old Section 197 was the lower-TDS certificate. Under the new Act that certificate moved to Section 395 (and the application is now Form 128, was Form 13) — while the number 197 has been reused for long-term capital gains. So "Section 197" means two completely different things depending on which Act someone is citing. When in doubt, ask which Act they mean.

What actually changed (not just the numbers)

A renumbering on its own is just admin. A few changes have teeth for NRIs:

DTAA claims are stricter. To claim a treaty rate you now expressly need a valid Tax Residency Certificate plus Form 41 (the old Form 10F), filed under Section 159(8). No TRC, no treaty rate — your bank withholds the full domestic rate until it is on file.

Foreign Tax Credit asks for a CA sign-off at scale. The FTC statement is now Form 44 (was Form 67), and where the foreign tax you are claiming is large (reported as ₹1 lakh or more), a Chartered Accountant's certificate goes with it.

The remittance gate is unchanged in substance. Sending money out of India still runs on the remitter declaration (now Form 145) and a CA certificate (now Form 146) for a taxable remittance over ₹5 lakh — same gate, new numbers.

Everything else for a typical NRI — the residence day-count, how Indian-source income is taxed, the DTAA rates themselves — carries over unchanged. The Act tidied the rule book; it did not rewrite your tax position.

What this means for you right now

If you are dealing with FY 2025-26 (the return you file in 2026): use the old forms — Form 10F, Form 15CA / 15CB, the ITR as before. Nothing to relearn for this filing.

If it is income from 1 April 2026 onward: it is the new forms. Filing Form 41 for your DTAA rate, selling property and applying for a lower-TDS certificate on Form 128, or remitting funds on Form 145 / 146 — those are the numbers your bank and CA will ask for.

If you are reading an older article or a bank email that still says "Form 10F" or "Section 197", it is not necessarily wrong — check which year and which Act it is talking about before you act on it.

Can you do this yourself?

Do it yourself

  • Work out which set applies: income up to 31 March 2026 uses the old forms; income from 1 April 2026 uses the new ones.
  • File Form 41 (the old Form 10F) yourself online to claim your DTAA rate — it is a short self-declaration on the income-tax portal.
  • Get your Tax Residency Certificate from your home country's tax authority; you need it on file before the treaty rate applies.
  • Check your annual tax statement, now Form 168 (the old Form 26AS), for the TDS credited against your PAN.

Where you need a CA

  • The remittance certificate (Form 146, old Form 15CB). By law a Chartered Accountant must certify a taxable foreign remittance — this one cannot be self-filed.
  • A lower-TDS certificate on a property sale (Form 128, old Form 13, under Section 395). The application turns on a capital-gains computation and supporting proof the assessing officer will scrutinise.
  • Foreign Tax Credit on Form 44 (old Form 67). Where the foreign tax is large the form needs a CA certificate, and the credit has to line up with your home-country return.
  • Matching an old notice or certificate to the new section numbers. An assessment for an earlier year runs under the old Act while new proceedings use the new one, and the numbers collide (old 197 versus new 197).

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Frequently asked questions

Common questions about The Income-tax Act 2025: what changed for NRIs (old vs new forms and sections)

For FY 2025-26 and earlier, yes — Form 10F is the form. From 1 April 2026 (Tax Year 2026-27) it is replaced by Form 41, filed online under Section 159(8) and Rule 75 of the Income-tax Rules, 2026. Same purpose: a self-declaration, filed with your Tax Residency Certificate, to claim your DTAA rate.

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Disclaimer: This page is for educational purposes only. The data shown is sourced from public AMFI / RBI / Income Tax Department / CBDT publications. We are not a SEBI-registered Investment Adviser and do not make product recommendations. For personalised tax or investment advice, please consult a qualified Chartered Accountant or SEBI-registered Investment Adviser. The country-by-country DTAA rates are based on India's notified treaties as of June 2026; treaty positions can change via protocol amendments and CBDT notifications.