Form 15CA vs 15CB: When NRIs Need Each Form

Form 15CA and Form 15CB arise in the Indian tax process for certain payments to a non-resident or foreign company. They do not set the CAD/INR rate, prove that a provider is cheapest, or replace the bank’s FEMA and KYC checks.

The correct form depends on who is paying, whether the amount is chargeable to tax in India, the aggregate amount in the financial year, whether an Assessing Officer order or certificate exists, and whether the transaction is excluded under Rule 37BB. A generic “all NRO transfers need 15CB” statement is too broad.

This article explains the official Income Tax Department FAQ and Rule 37BB framework. It is not a certificate and cannot decide whether a particular remittance is chargeable.

Form 15CA is information furnished by the person responsible for making a payment to a non-resident, not being a company, or to a foreign company, subject to the rule’s conditions and exceptions. The remitter provides information about the payment and its tax treatment.

The official FAQ describes four parts. Part A is for a chargeable remittance where the amount or aggregate during the financial year does not exceed ₹5 lakh. Part B is used where the amount exceeds ₹5 lakh and an Assessing Officer order or certificate under the relevant provisions has been obtained. Part C is used where the amount exceeds ₹5 lakh and Form 15CB from an accountant is required. Part D is for a sum not chargeable to tax, subject to Rule 37BB.

Part labels are not a shortcut: the chargeability analysis comes first. The bank or authorised dealer may also have its own document checklist.

Form 15CB is an accountant’s certificate for a qualifying chargeable payment exceeding ₹5 lakh in aggregate during the financial year when an Assessing Officer order or certificate is not obtained. The accountant examines matters such as chargeability, taxability, rate, and withholding under the applicable provisions.

The Income Tax Department FAQ says 15CB is not mandatory for every remittance. It is event-based and is required for the relevant Part C route. A professional should decide whether the payment is chargeable and whether Part B, Part C, or another route applies.

A CA certificate does not turn a non-compliant source into a compliant one. Keep the agreement, invoice, account statement, tax computation, source evidence, and any order or certificate that supports the form.

The 15CA/15CB threshold discussed in Rule 37BB is a ₹5 lakh aggregate threshold for the relevant financial-year payments to a non-resident. The LRS TCS threshold is a separate ₹10 lakh aggregate threshold for an Indian resident’s specified outward LRS remittances. They answer different legal questions.

Do not copy the LRS TCS rate into a 15CA calculation, and do not assume that crossing the 15CA threshold creates TCS. A payment can require form analysis without being an LRS remittance, and an LRS remittance can have a TCS question separate from a Form 15CA/15CB question.

If a bank asks for both a TCS calculation and a 15CA/15CB document, treat the requests as separate workstreams and ask what provision supports each.

Rule 37BB includes specified transactions for which Form 15CA information is not required. The exception list and conditions must be checked against the current rule; do not infer an exception merely because the payment is a gift, family support, property-related, or sent from an NRO account.

A payment that is not chargeable may still require Part D unless it falls within an applicable exception. The official FAQ and current rule should be read together, and the bank may ask for a declaration or purpose evidence.

For an NRO repatriation, ask the authorised dealer what it needs for tax compliance, source of funds, account history, TDS, and FEMA. The RBI’s USD 1 million facility is conditional and does not answer the tax-form question by itself.

Record the payer and recipient status, recipient country, payment nature, contract or property document, gross amount, financial-year aggregate, currency, taxability, applicable treaty article if relevant, and any prior remittances. Keep the bank’s requested purpose code and account details.

If using Part C, obtain Form 15CB from an eligible accountant before completing the linked Part C submission. If an Assessing Officer order or certificate exists, ask the bank whether Part B is the correct route. If the payment is non-chargeable, document why Part D or an exception applies.

Submit through the official income-tax portal or the route specified by the bank. Verify the acknowledgement and link it to the outward remittance record. Do not upload identity or tax documents through an unverified link.

15CA and 15CB generally matter to an Indian outward payment to a non-resident, such as repatriating eligible Indian funds to Canada. They are not blanket forms for a Canadian sender depositing CAD into India. Direction, payer, recipient, purpose, and chargeability are the first questions.

For TCS on an India-resident LRS payment, read the current TCS guide. For Canada-side international EFT reporting and India’s outward/inward distinction, read the large-transfer guide. For the Canadian resident’s foreign-property questions, read the NRI tax guide.

For amount-specific records, use the small INR, mid-size INR, and large INR guides.

For the regulatory side, read the NRI tax guide, large-transfer guide, TCS on LRS guide, and Form 15CA versus 15CB guide. Amount-specific record checklists are in the small INR, mid-size INR, and large INR guides.

Continue with the cost comparison, the bank-versus-online guide, or the CAD versus USD analysis. For amount-specific checklists, see the small CAD, routine CAD, large CAD, and major CAD guides.