Form 145 (Previously 15CA) Part A Explained
Learn when Form 145 (Previously 15CA) Part A applies, understand the ₹5 lakh aggregate threshold, required information, filing considerations and when Form 146 (Previously 15CB) is not required.
For smaller taxable foreign remittances, Form 145 (Previously 15CA) Part A is generally the starting point to understand.
Under Rule 220 of the Income-tax Rules, 2026, Part A applies where the amount of payment or aggregate of such payments made during the tax year does not exceed ₹5 lakh.
When Is Part A Used?
Consider an Indian company making a taxable payment of ₹3 lakh to a foreign service provider.
If the relevant conditions are satisfied and the aggregate of qualifying payments during the tax year does not exceed ₹5 lakh, the taxpayer can fall under Part A.
The important word is aggregate.
It is therefore not always enough to look at only one invoice.
Example
Suppose a company makes:
- April – ₹1.5 lakh
- July – ₹1 lakh
- November – ₹1.25 lakh
Total = ₹3.75 lakh
If the payments fall within the scope of Rule 220 and are chargeable under the Act, the aggregate remains below ₹5 lakh.
Part A may therefore be applicable.
What Information Is Required?
Part A broadly captures information relating to:
- Remitter
- Remittee
- Remittance
- Declaration
The taxpayer should have the underlying transaction documents and payment details ready before starting the filing.
What If the Next Payment Takes the Total Above ₹5 Lakh?
This is where businesses need to be careful.
Suppose the aggregate reaches ₹4.8 lakh and another qualifying payment of ₹1 lakh is proposed.
The aggregate would become ₹5.8 lakh.
The taxpayer should therefore reassess the applicable provision and filing route rather than treating every transaction independently.
Is Form 146 (Previously 15CB) Required?
Part A itself does not require Form 146.
Form 146 (Previously 15CB) becomes relevant to the Part C route for qualifying taxable remittances exceeding ₹5 lakh.
Final Takeaway
Part A is designed for qualifying taxable remittances where the payment or aggregate of payments during the tax year does not exceed ₹5 lakh.
The ₹5 lakh limit should be considered carefully because the rule refers to the aggregate of such payments during the tax year