When clients make foreign remittances, compliance under the Income Tax Act and FEMA becomes critical. As Chartered Accountants, filing Form 15CB and facilitating the generation of Form 15CA is a regular but sensitive task, given the implications of incorrect reporting.

This guide explains the process, key checks, and practical considerations while handling Form 15CB and Form 15CA for your clients.

Understanding the Forms

Form 15CB is a certificate issued by a Chartered Accountant under Rule 37BB of the Income Tax Rules. It certifies the nature of the remittance and that the applicable tax has been correctly deducted under the provisions of the Income Tax Act.

Form 15CA is a declaration by the remitter, filed online on the Income Tax Portal. It is often based on the information provided in Form 15CB.

When is Form 15CB Required?

Form 15CB is required in the following cases:

• The remittance exceeds ₹5 lakh in a financial year and

• It is not covered under the list of 33 items in Rule 37BB, which are exempt from furnishing Form 15CA/15CB.

If the payment is covered under the exempt list or below the threshold, only Part A or B of Form 15CA may be applicable.

Steps to File Form 15CB and Generate Form 15CA

Step 1: Obtain Documents from the Client

Before filing, collect:

• Invoice or agreement for the remittance

• PAN and bank details of the remitter and remittee

• Nature and purpose of remittance

• FEMA classification

• Tax Residency Certificate (TRC) of the recipient, if DTAA is to be applied

• Any withholding tax rate confirmations

Step 2: Review the Transaction

As a CA, verify:

• Nature of payment and applicable section under the Income Tax Act

• Rate of TDS under the domestic law and DTAA

• Availability of PAN for the non-resident

• Whether the payment is taxable in India

If DTAA benefit is claimed, ensure all documentation is in place, including Form 10F and a self-declaration of beneficial ownership.

Step 3: File Form 15CB (CA Portal)

• Log in to e-Filing Portal

• Go to "e-File" > "Income Tax Forms" > "File Income Tax Forms"

• Select Form 15CB

• Fill in the form with remitter and remittee details, nature of remittance, TDS computation, bank information, and attach supporting documents

• Sign using DSC and submit

Once filed, the Form 15CB Acknowledgement Number is generated.

Step 4: Generate Form 15CA (Client's Account)

• The client logs in with their credentials on the e-Filing portal

• Navigate to "e-File" > "Income Tax Forms" > "File Income Tax Forms"

• Select Form 15CA and choose the appropriate Part (A, B, C, or D)

• For Part C, enter the Acknowledgement Number of Form 15CB filed by the CA

• Complete the details, verify via EVC/DSC, and submit

A copy of Form 15CA can then be downloaded and submitted to the bank along with Form 15CB.

Practical Tips for CAs

• Always cross-check whether the payment falls under the exempt list of Rule 37BB before initiating the 15CB process.

• Advise clients to initiate the 15CB process early, as banks often reject remittance without both forms.

• Keep a checklist ready for standard documentation to avoid back-and-forth delays.

• Review DTAA applicability carefully, especially in cases of professional services, royalties, or technical fees.

• Retain signed copies of both forms for audit and compliance records.

Common Mistakes to Avoid

• Filing 15CB without adequate backup for DTAA claims

• Using incorrect section under the Income Tax Act for TDS deduction

• Incorrect classification of the nature of remittance in Form 15CA

• Mismatch of values between Form 15CB and Form 15CA

• Filing 15CB when not required, leading to unnecessary compliance burden

Conclusion

Handling Form 15CB and 15CA is more than a procedural task—it requires sound tax judgment, documentation review, and an understanding of cross-border regulations. A well-designed internal process within the CA firm, combined with a standard checklist for client communication, can help streamline this activity and ensure full compliance.