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Forms Under ITA 1961 vs ITA 2025 | CGK & Co
Forms Reference Guide

ITA 1961 → ITA 2025
Complete Forms Comparison

A comprehensive visual guide to every statutory form that changes under the Income Tax Act, 2025 — what it was, what it becomes, and exactly what is different. Effective 1 April 2026.

399
Forms under ITA 1961
190
Forms under ITA 2025
52%
Reduction in forms
1 Apr
Effective date 2026
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Legend
Old Act (ITA 1961)
New Act (ITA 2025)
Key changes
No change in substance
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PAN & TAN Applications
4 forms
Form 49A Form 93
PAN Application — Indian Individuals
Application for allotment of Permanent Account Number by Indian citizens
PAN
ITA 1961 — Form 49A
Who files
All Indian individuals, companies, and entities — a single multi-purpose form for all applicants
Governing section
Section 139A, Income Tax Act, 1961
Structure
One combined form covering all categories of applicants — individuals, companies, trusts, etc. Many fields irrelevant to specific categories
When to use
For all PAN applications filed on or before 31 March 2026
ITA 2025 — Form 93
Who files
Indian individuals (citizens of India) only — category-specific form
Governing section
Section 239, Income Tax Act, 2025
Structure
Streamlined — contains only fields relevant to individual applicants. Removes fields applicable only to companies or entities
When to use
For all new PAN applications filed on or after 1 April 2026 by Indian individual citizens
Key Changes
Form split by applicant category — individuals get a dedicated form
Fewer irrelevant fields — only individual-specific information required
Existing PANs remain valid — no reapplication needed
Form 49A Form 94
PAN Application — Indian Companies & Entities
Application by companies, firms, trusts, and entities incorporated or formed in India
PAN
ITA 1961 — Form 49A
Who files
All applicants including companies, firms, trusts, AOP, BOI — same form as individuals
Issue
Individuals and entities used the same form, causing confusion and unnecessary fields for each category
When to use
For all PAN applications filed on or before 31 March 2026
ITA 2025 — Form 94
Who files
Indian companies, firms, LLPs, trusts, AOPs, BOIs, and all other entities incorporated or formed in India
Improvement
Entity-specific fields — registration details, authorised signatory, and entity type fields are tailored precisely
When to use
For all new PAN applications by Indian entities filed on or after 1 April 2026
Key Changes
Separated from individual PAN form — entities now have a dedicated Form 94
Entity-specific fields only — no individual personal details required
Existing PAN numbers remain valid
Form 49AA Form 95
PAN Application — Foreign Individuals
Application by individuals who are not citizens of India
PAN
ITA 1961 — Form 49AA
Who files
Individuals not being citizens of India, and entities incorporated outside India — combined in one form
Governing section
Section 139A, Income Tax Act, 1961
Issue
Foreign individuals and foreign entities shared one form despite very different information requirements
ITA 2025 — Form 95
Who files
Individuals not being citizens of India — only. Foreign entities now have a separate Form 96
Governing section
Section 239, Income Tax Act, 2025
Improvement
Individual-specific fields for passport details, country of residence, and foreign tax identification — no entity clutter
Key Changes
Split from entity form — foreign individuals and entities now have separate forms
Passport and foreign ID fields streamlined for individual applicants
Form 49AA Form 96
PAN Application — Foreign Entities
Application by entities incorporated or formed outside India
PAN
ITA 1961 — Form 49AA
Who files
Entities incorporated outside India — previously combined with foreign individuals in one form
Issue
Foreign companies, trusts, and partnerships shared form space with foreign individuals despite different information needs
ITA 2025 — Form 96
Who files
Entities incorporated or formed outside India — companies, trusts, partnerships, funds registered abroad
Improvement
Entity registration details, country of incorporation, and authorised representative fields are clearly structured for foreign entities specifically
Key Changes
Dedicated form for foreign entities — separated from foreign individual form
Entity-specific foreign registration fields clearly structured
TAN Applications
2 forms
Form 49B Form 134
TAN Application — Government Entities
Application for Tax Deduction Account Number by government deductors
TAN
ITA 1961 — Form 49B
Who files
All deductors — government entities, companies, individuals, firms — all in one combined form
Issue
Government entities required to provide AIN and PAO/ZAO/DTO/CDDO certificate alongside all other applicants in the same form — cluttered and confusing
ITA 2025 — Form 134
Who files
Government entities only — central and state government departments, PSUs, and government bodies
Specific fields
Mandatory AIN field and PAO/ZAO/DTO/CDDO certificate requirement built directly into form structure — no ambiguity
When to use
All fresh TAN applications by government entities from 1 April 2026
Key Changes
Government-only form — separated from private sector applicants
AIN and PAO/ZAO/DTO/CDDO certificate fields mandatory and clearly structured
Existing TANs remain valid
Form 49B Form 135
TAN Application — Non-Government Entities
Application by individuals, HUFs, companies, firms, LLPs, and other private deductors
TAN
ITA 1961 — Form 49B
Who files
All deductors including private companies, individuals, HUFs, firms — same form as government entities
Issue
Private sector applicants had to navigate government-specific fields (AIN, PAO certificates) that were not applicable to them
ITA 2025 — Form 135
Who files
All non-government deductors — individuals, HUFs, companies, LLPs, firms, statutory bodies, and private entities
Improvement
No government-specific fields — cleaner form tailored to private sector deductors only
When to use
All fresh TAN applications by private entities from 1 April 2026
Key Changes
Private sector only — no government fields cluttering the form
Streamlined entity type selection for private applicants
TDS / TCS Compliance Forms
6 forms
15G / 15H Form 121
Self-Declaration for Nil TDS
Declaration by recipient that estimated income is below taxable threshold — applicable to banks, FDs, etc.
TDS
ITA 1961 — Forms 15G & 15H
Who files
Form 15G: Resident individuals below 60 years and eligible non-individual entities. Form 15H: Resident individuals aged 60 years or more (senior citizens)
Governing section
Section 197A, Income Tax Act, 1961
UIN system
Each payer generated a separate UIN for every declaration received — even for the same PAN in the same year. Caused massive duplication
Issue
Two separate forms caused confusion — taxpayers often unsure which form applied to them. Age-based split not intuitive
ITA 2025 — Form 121
Who files
All eligible declarants — individuals of any age and other eligible persons. Single unified form replaces both 15G and 15H
Governing section
Section 393(6), Income Tax Act, 2025
UIN system
Single UIN issued per PAN per tax year by the department. All declarations from same taxpayer to different payers linked to one UIN — no duplication
When to use
For Tax Year 2026–27 onwards. For AY 2026–27 and earlier, old Forms 15G/15H apply
Key Changes
Two forms merged into one — zero ambiguity on which form to use
Single UIN per PAN per year — eliminates duplication across multiple payers
Payers can fetch UIN directly from departmental portal
Eligibility criteria unchanged — income threshold and residency conditions same
Form 13 Form 128
Lower / Nil Withholding Certificate
Application to Assessing Officer for certificate authorising TDS at lower or nil rate
TDS
ITA 1961 — Form 13
Who files
Payees (recipients of income) applying for lower/nil TDS deduction where total income justifies it
Governing section
Section 197, Income Tax Act, 1961
Process
Filed via TRACES portal. AO issues certificate specifying applicable rate and validity period
Transition note
Certificates issued under old Act for TY 2026–27 remain valid for payments/credits on or after 1 April 2026
ITA 2025 — Form 128
Who files
Same — payees applying for lower or nil deduction of tax for Tax Year 2026–27 onwards
Governing section
Section 395(1), Income Tax Act, 2025
Process
Filed via TRACES or e-filing portal — same process, new form number. AO issues certificate as before
When to use
From 1 April 2026 for new applications. Existing Form 13 certificates issued for TY 2026–27 remain valid
Key Changes
Form number changes — substantive process and eligibility unchanged
Existing certificates valid — no reapplication needed if already issued for TY 2026–27
AO process and TRACES portal unchanged
Form 15CA Form 145
Foreign Remittance Declaration
Declaration by remitter for payments made to non-residents — nature of remittance and applicable TDS
NRI
ITA 1961 — Form 15CA
Who files
Any person making a payment to a non-resident where such payment is taxable in India
Governing section
Section 195(6), Income Tax Act, 1961
Structure
Four parts: Part A (small remittances), Part B (AO certificate obtained), Part C (CA certificate obtained), Part D (non-taxable remittances). If Part B filed, Part C still required — duplication
Validity
Valid up to proposed remittance date. If remittance not made by that date, fresh form required
ITA 2025 — Form 145
Who files
Same — remitters making payments to non-residents for Tax Year 2026–27 onwards
Governing section
Section 397(3)(d), Income Tax Act, 2025
Key improvement
If Part B filed (AO certificate obtained), Part C (CA certificate) is NOT required. Eliminates duplication that existed under old Act — significant reduction in compliance cost
When to use
For all remittances made on or after 1 April 2026. Earlier remittances use old Form 15CA
Key Changes
AO certificate (Part B) makes CA certificate (Part C) unnecessary — no duplication
Significant cost and compliance burden reduction for frequent remitters
Four-part structure retained — Part A, B, C, D logic same
Threshold of Rs. 5 lakh for CA certificate unchanged
Form 15CB Form 146
CA Certificate for Foreign Remittance
Chartered Accountant certificate confirming nature of remittance, DTAA provisions, and applicable TDS rate
NRI
ITA 1961 — Form 15CB
Who issues
Chartered Accountant — certifying nature of payment, applicable DTAA article, and TDS rate
When required
Required whenever Form 15CA Part C is filed — i.e., taxable remittances exceeding Rs. 5 lakh without an AO certificate
Verification
No real-time verification mechanism — potential for misuse
ITA 2025 — Form 146
Who issues
Chartered Accountant — same role, new form number
When required
Only when Part C of Form 145 is filed. NOT required if Part B (AO certificate) is filed — key change
UDIN introduced
Unique Document Identification Number (UDIN) now mandatory — real-time verification via ICAI API ensures authenticity and prevents fraud
Key Changes
UDIN mandatory — real-time CA certificate verification via ICAI API
Not required when AO certificate obtained — reduces burden for remitters
CA certification role and content requirements unchanged
Form 60 Form 97
Declaration Where PAN Not Available
Filed by persons without PAN who wish to undertake specified high-value transactions
Other
ITA 1961 — Form 60
Purpose
Allows persons without PAN to transact in specified high-value transactions listed under Rule 114B and 114BA
When filed
At the time of undertaking the specified transaction
Who maintains record
Receiving entity — required to file half-yearly statement in Form 61
ITA 2025 — Form 97
Purpose
Same — allows persons without PAN to undertake specified transactions under Rule 159(2) of Income Tax Rules, 2026
When filed
At the time of undertaking the specified transaction — unchanged
Note
Scope of specified transactions in Rule 159(2) has some changes compared to Rule 114B — verify specific transaction coverage under new rules
Key Changes
Form number changes — Form 60 becomes Form 97
Scope of covered transactions slightly modified — check Rule 159(2)
Timing of filing unchanged — at point of transaction
Form 61 Form 98
Half-Yearly Statement of Declarations Received
Filed by reporting entities who received Form 60 / Form 97 declarations from parties without PAN
Other
ITA 1961 — Form 61
Who files
Every person who received Form 60 declarations during the half-year period
Due dates
Apr–Sep period: 31 October. Oct–Mar period: 30 April of following year
Governing rule
Rule 114D of Income Tax Rules, 1962
ITA 2025 — Form 98
Who files
Every reporting entity that received Form 97 declarations during the half-year period
Due dates
Apr–Sep period: 31 October. Oct–Mar period: 30 April — unchanged
Governing rule
Income Tax Rules, 2026
Key Changes
Form number changes — Form 61 becomes Form 98
Due dates unchanged — 31 Oct and 30 Apr
Filing obligation and process unchanged
Tax Audit & Compliance Reports
3 forms merged into 1
3CA / 3CB / 3CD Form 26
Tax Audit Report
Audit report and statement of particulars under the tax audit requirement — three forms unified into one
Audit
ITA 1961 — Forms 3CA, 3CB & 3CD
Structure
Three separate forms: Form 3CA (for persons whose accounts are already audited under another law), Form 3CB (for all others), Form 3CD (detailed statement of particulars — attached with both 3CA and 3CB)
Governing section
Section 44AB, Income Tax Act, 1961
Disallowance reporting
Item-wise detailed reporting of disallowable expenditure — fragmented across multiple clauses
Due date AY 2026–27
30 September 2026 (one month before ITR due date of 31 October 2026)
UDIN
Required but manually entered — no real-time API verification
ITA 2025 — Form 26
Structure
Single unified smart form — merges all three erstwhile forms. Structured and standardised reporting with separate schedules for Losses, Depreciation, Deductions, Prior Period items, and Computation of receipts/expenses
Governing section
Section 63, Income Tax Act, 2025
Disallowance reporting
Single consolidated disclosure of disallowable expenditure — rationalised and aligned with ITR framework
Due date TY 2026–27
30 September 2027
UDIN
Mandatory with real-time ICAI API verification — auditor membership number and firm registration number also mandatory
Key Changes
Three forms → one unified Form 26 — major simplification
Separate schedules for losses, depreciation, deductions, prior period
Consolidated disallowance disclosure — no more item-wise fragmented reporting
UDIN with real-time ICAI API verification — mandatory
Dedicated fields for capital receipts and deemed incomes not in P&L
Audit thresholds unchanged — Rs. 1 Cr (business), Rs. 10 Cr (digital), Rs. 50 lakh (profession)
Salary & Other Relief Forms
2 forms
Form 10E Form 39
Relief for Salary Arrears / Advance
Filed to claim relief from higher tax liability arising from receipt of salary in arrears, advance, gratuity, or commuted pension
Relief
ITA 1961 — Form 10E
Governing section
Section 89(1), Income Tax Act, 1961
Structure
Required repeated entry of same personal and financial details — no pre-population. Taxpayers frequently made errors in computation tables
Computation
No structured computation tables — taxpayers computed relief manually, leading to frequent errors and confusion
Due date
On or before ITR due date. Required for AY 2026–27 — use Form 10E
ITA 2025 — Form 39
Governing section
Section 157, Income Tax Act, 2025
Structure
Part A: Basic details (auto-populated). Part B: Receipt details with uniform computation tables per category. Smart interface with drop-downs, date pickers, and real-time validation
Computation
Structured computation tables per receipt type (arrears, gratuity, pension, retrenchment compensation) with formulas built in — system-based validation
When to use
Tax Year 2026–27 onwards only. For AY 2026–27, use old Form 10E
Key Changes
Auto-population of taxpayer data — no repeated manual entry
Structured computation tables per receipt category with built-in formulas
Real-time validation and system-based verification
Part A / Part B structured format eliminates repeated data entry
Relief mechanism and eligibility unchanged
Charitable Trust Registration
1 form
Form 10A Form 104
Provisional Registration — Charitable Trust
Application for provisional registration or approval by charitable organisations, trusts, and institutions
Trust
ITA 1961 — Form 10A
Who files
Charitable organisations, trusts, and institutions applying for provisional registration or approval
Information required
Detailed breakdown of total income, details of religious expenditure for past three years, full asset and liability statement — regardless of whether return was filed
Length
Lengthy and complex — significant compliance burden for small charitable organisations
Transition
Applications pending as on 31 March 2026 will be disposed of under old Act — no fresh application required
ITA 2025 — Form 104
Who files
Same — charitable organisations, trusts, and institutions. All fresh applications from 1 April 2026 use Form 104
Information required
Asset and liability details removed from main form — only required if return of income not filed. Income breakdown and religious expenditure details for past three years removed entirely
Length
Substantially simplified and significantly shorter — major reduction in compliance burden
Existing registrations
Registrations granted under old Act remain valid — no re-registration required unless inconsistent with new Act
Key Changes
Asset/liability details removed from main form — only if no ITR filed
Income breakdown and religious expenditure for past 3 years removed entirely
Substantially shorter — significant reduction in compliance burden
Existing registrations valid — no reapplication needed
Pending applications disposed of under old Act
Quick Reference — All Forms at a Glance
Purpose Old Form (ITA 1961) New Form (ITA 2025) Effective
PAN — Indian Individual Form 49A Form 93 1 Apr 2026
PAN — Indian Company / Entity Form 49A Form 94 1 Apr 2026
PAN — Foreign Individual Form 49AA Form 95 1 Apr 2026
PAN — Foreign Entity Form 49AA Form 96 1 Apr 2026
TAN — Government Entity Form 49B Form 134 1 Apr 2026
TAN — Non-Government Entity Form 49B Form 135 1 Apr 2026
Nil TDS Self-Declaration (below 60 yrs) Form 15G Form 121 TY 2026–27
Nil TDS Self-Declaration (60 yrs+) Form 15H Form 121 TY 2026–27
Lower / Nil Withholding Certificate Form 13 Form 128 1 Apr 2026
Foreign Remittance Declaration Form 15CA Form 145 1 Apr 2026
CA Certificate for Foreign Remittance Form 15CB Form 146 1 Apr 2026
Declaration — No PAN Form 60 Form 97 1 Apr 2026
Half-Yearly Statement of Declarations Form 61 Form 98 1 Apr 2026
Tax Audit Report 3CA + 3CB + 3CD Form 26 TY 2026–27
Salary Arrears Relief Form 10E Form 39 TY 2026–27
Charitable Trust Registration Form 10A Form 104 1 Apr 2026
Disclaimer
This reference guide is compiled from CBDT’s official FAQs on Interplay and Transition from the Income Tax Act, 1961 to the Income Tax Act, 2025. It is for general information only and does not constitute professional advice. In the event of any conflict, statutory provisions shall prevail. For advice specific to your situation, consult a qualified Chartered Accountant.
CGK & Co, Chartered Accountants  ·  Secunderabad, Telangana
enquiries@cgkandco.in  ·  040-27843997  ·  9436216326  ·  cgkandco.in

© CGK & Co 2026. For general reference only. Statutory provisions prevail.