Form 15CA/15CB Part A vs B vs C: When 15CB Is Mandatory Before Remittance

Part A is for remittances up to ₹5 lakh in the financial year; once your taxable remittances cross ₹5 lakh, you need a CA's Form 15CB certificate first and must file Part C. This is the heart of Rule 37BB of the Income Tax Rules 1962, read with s.195 of the Income Tax Act 1961. Part D covers remittances not chargeable to Indian tax at all, and Part B applies only where you already hold an Assessing Officer (AO) order. Your bank will not process a covered remittance without the correct form, and failure to file attracts a ₹1 lakh penalty under s.271-I.

The Four Parts of Form 15CA at a Glance

Rule 37BB(3) also exempts a specified list of remittances (personal travel, education abroad, medical treatment, maintenance of relatives, imports, and similar categories) from filing any form, regardless of amount.

Part A or Part B? Deciding Your Route

• Choose Part A if the remittance, or the total of remittances in the FY, is ₹5 lakh or less. File it yourself on the income-tax portal — no CA, no 15CB.
• Choose Part B only if the remittance exceeds ₹5 lakh and you have already obtained a lower-deduction or nil-withholding order from the AO under s.195(2), 195(3) or 197. This is the rare route — most remitters never hold such an order.
• Choose Part C if the remittance exceeds ₹5 lakh, is chargeable to tax, and you have no AO order — the standard position. This is the only route that requires a CA's Form 15CB certificate, obtained before you file.
• Choose Part D if the remittance is not chargeable to tax — for example, repatriation of your own after-tax NRO funds. You self-file Part D.

What the CA Actually Certifies in Form 15CB

Form 15CB is the chartered accountant's certificate confirming, before the bank releases the funds:

• The nature of the payment (service fee, royalty, dividend, capital gain, etc.) and its tax treatment in India.
• Whether the payment is chargeable to tax and under which section.
• The DTAA position — whether a treaty rate applies, backed by the payee's Tax Residency Certificate and Form 10F.
• The TDS to be deducted under s.195, and confirmation that it will be deducted and deposited.

The bank treats the filed Form 15CA (with the 15CB reference) as its compliance proof. Without it, the remittance is not processed.

Worked Example: Kavita's Two Remittances in One Year

Kavita, an Indian resident, pays a UK-based software consultant in FY 2025-26:

• August 2025: ₹4,00,000 for services rendered in India.
• November 2025: ₹3,00,000 for further services.

First remittance (₹4,00,000): Her FY total is ₹4 lakh — Part A, self-filed, no 15CB.

Second remittance (₹3,00,000): Her FY aggregate is now ₹7,00,000 — above the ₹5 lakh threshold. The payment is chargeable to tax (fees for technical services, s.9(1)(vii)). She holds no AO order. So she must:

• Engage a CA to issue Form 15CB certifying the nature, the DTAA position (India-UK treaty), and the TDS to be withheld.
• File Part C of Form 15CA on the portal referencing the 15CB.
• Hand the acknowledgement to her bank before the transfer.

The penalty if she skips it: failure to furnish Form 15CA/15CB, or furnishing inaccurate information, attracts a penalty of ₹1,00,000 under s.271-I — payable in addition to the tax and TDS interest on the underlying payment.

Changed FY 2025-26: Under the Income-tax Act 2025, effective 1 April 2026, Form 15CA becomes Form 145 and Form 15CB becomes Form 146 for new remittances. The rules, the ₹5 lakh threshold and the four-part structure are unchanged, and filings made before 1 April 2026 on Forms 15CA/15CB remain valid. Returns for FY 2025-26 (AY 2026-27) continue to use the 1961 Act forms.

The ₹5 Lakh Test Is an Annual Aggregate

The ₹5 lakh limit is the total of remittances in the financial year, not a per-transaction figure. Four taxable remittances of ₹1.5 lakh each add up to ₹6 lakh and push you from Part A into Part C territory. Splitting a ₹7 lakh payment into two ₹3.5 lakh transfers to "stay under five lakh" does not work — the aggregate crosses the threshold.

Bank vs Law: What Actually Blocks the Transfer

The law sets the floor of what you must file. Your bank (authorised dealer) is entitled to demand more documentation for its own risk management — and it commonly asks for a 15CB even on a Part D self-declaration. Knowing which requirement is legal (Part C needs 15CB) and which is the bank's internal policy (a certificate demanded on Part D) lets you negotiate instead of paying for every certificate requested.

FAQ

Q1: What is the difference between Part A and Part B of Form 15CA?
Part A applies to remittances of ₹5 lakh or less in the FY (self-filed, no 15CB). Part B applies to remittances above ₹5 lakh where you already hold an AO certificate/order under s.195(2), 195(3) or 197 — the rare route where the AO order replaces the 15CB.

Q2: When is Form 15CB (CA certificate) mandatory?
Only for a remittance that is chargeable to tax and exceeds ₹5 lakh in the FY, where you have no AO order — that is Part C of Form 15CA. Below ₹5 lakh (Part A), with an AO order (Part B), or where the remittance is not taxable (Part D), no 15CB is required.

Q3: I am an NRI repatriating my own after-tax NRO funds. Which part do I file?
Part D, as the remittance is generally not chargeable to tax again. Your bank may still ask for a CA certificate as its own policy — that is the bank's requirement, not the law's.

Q4: What is the penalty for not filing Form 15CA/15CB?
Failure to furnish, or furnishing inaccurate information, attracts a penalty of ₹1,00,000 under s.271-I of the Income Tax Act 1961.

Q5: Is the ₹5 lakh limit per transaction or per year?
Per financial year, as an aggregate. All taxable remittances in the year are added; once the total crosses ₹5 lakh, the next remittance is filed under Part C with a 15CB.

Q6: Which remittances need no form at all?
Rule 37BB(3) lists specified remittances — personal travel, education, medical treatment, maintenance of close relatives, imports, and similar — that are exempt from filing any form, regardless of amount.

Q7: Does the bank need the acknowledgement before releasing funds?
Yes. For a covered remittance, the bank (authorised dealer) requires the filed Form 15CA acknowledgement (and the 15CB reference where applicable) before processing the transfer. No form, no remittance.

Use our Form 15CA/CB Decision Tree to identify your part and the documents you need before you approach the bank.

Sources

• Rule 37BB, Income-tax Rules 1962 — Form 15CA parts and exempt remittances.
• Section 195, Income-tax Act 1961 — deduction of tax on payments to non-residents.
• Section 271-I, Income-tax Act 1961 — ₹1 lakh penalty for non-compliance.
• Income-tax Act 2025 — Forms 145/146 renumbering effective 1 April 2026.

File the right part before the bank does, and keep the acknowledgement — it is your proof if the remittance is questioned later. Book a consultation at harunraaj.com.

Need help with this?

Our team handles the paperwork. You focus on your business.