Do You Need Form 146 (Previously 15CB) If You Have an AO Certificate?

Do You Need Form 146 (Previously 15CB) If You Have an AO Certificate?

Do you need Form 146 (Previously 15CB) with an AO certificate? Learn the difference between Form 145 (Previously 15CB) Part B and Part C and when a CA certificate is or isn't required.

20 Aug 2026•
11 min read

One of the common questions under the new Form 145 framework is whether a taxpayer needs to obtain both an Assessing Officer's certificate and Form 146 when the foreign remittance exceeds ₹5 lakh.

The answer is No.

The new Income-tax Rules, 2026 specifically remove this duplication.

First, Understand Part B and Part C

For taxable foreign remittances exceeding ₹5 lakh during the tax year, two different routes are available under Rule 220.

Part B

Part B applies where the remittance exceeds ₹5 lakh and the taxpayer has obtained the required certificate or order from the Assessing Officer under the relevant provision.

Part C

Part C applies where the remittance exceeds ₹5 lakh and the taxpayer has obtained a Form 146 certificate from an accountant.

So What Happens If You Have an AO Certificate?

If the taxpayer furnishes the required information in Part B, there is no need to additionally furnish Part C.

In other words:

AO Certificate → Form 145 Part B

not

AO Certificate → Part B + Form 146 + Part C

The Income Tax Department specifically states that where information in Part B has been furnished, information in Part C is not required.

Example

Suppose an Indian company has a taxable foreign remittance of ₹15 lakh.

The company obtains the applicable certificate/order from the Assessing Officer.

It can proceed through:

AO Certificate → Form 145 Part B → Submission

It does not need to separately approach a CA for Form 146 merely for this purpose.

Why Is This Important?

Under the new framework, this removes duplicate compliance.

A taxpayer should therefore first understand which route applies rather than automatically assuming that every remittance above ₹5 lakh requires a CA certificate.

Part B vs Part C

Situation - Remittance > ₹5 lakh + AO certificate/order

Form 145 Part- Part B

Form 146 - Not required

Situation - Remittance > ₹5 lakh + accountant's certificate

Form 145 Part - Part C

Form 146 - Required

The correct route depends on the documentation available and the circumstances of the remittance.

Final Takeaway

If you already have the applicable AO certificate/order and are filing Form 145 Part B, you do not need to obtain Form 146 or also complete Part C