On 28 September 2026 the Central Board of Direct Taxes moved the return deadline for audited taxpayers to 21 November 2026, in Circular 07/2026. For many business-owning clients of CAs and wealth advisors, that return will claim tax collected at source on foreign remittances made before April. The certificate behind that credit is Form 27D, the TCS certificate under the Income-tax Act, 1961, and it has not disappeared just because Form 133 replaced it for new collections.
The point is easy to miss. Most of this year's commentary has been about the new forms that arrived with the Income-tax Act, 2025, so clients assume the old numbers are history. They are not, because the return now being filed covers financial year 2025-26, and every rupee of TCS in it was collected under the old law and reported on Form 27D. Advisors who check those certificates against the annual tax statement before filing will avoid most of the mismatches that delay refunds, and our guide to TCS on foreign remittance sets out the wider rules.
What Form 27D is and who issues it
Form 27D is the certificate a collector gives a collectee to show that tax was collected at source and paid to the government. It was issued under section 206C of the Income-tax Act, 1961 and Rule 37D of the Income-tax Rules, 1962. For an advisor's clients, the collector is usually the authorised dealer bank that handled a remittance under the Liberalised Remittance Scheme, the RBI framework that lets a resident individual send up to USD 250,000 abroad in a financial year. Car dealers, tour operators and sellers of certain goods also collect TCS, so a client may hold more than one certificate.
The certificate is quarterly. According to the TRACES help pages, the collector had to issue it within 15 days of the due date for filing the quarterly TCS statement, Form 27EQ, and a certificate downloaded from TRACES is the valid one under CBDT Circular 04/2013. The PDF carries the collector's TAN, the client's PAN, the amount received, the tax collected and the deposit details. A typed letter from a bank saying the same thing is not a substitute.
Why Form 27D still matters after the move to Form 133
From 1 April 2026, collections fall under section 394 of the Income-tax Act, 2025, and the certificate is Form 133 under Rule 215 of the Income-tax Rules, 2026, according to the Income Tax Department's Form 133 FAQs. The quarterly statement that feeds it is now Form 143, which replaced Form 27EQ. Our earlier note on Form 133 and TCS certificates in 2026-27 explains the new timetable in detail.
The switch is decided by date, not by when the paperwork is done. The department's FAQs on the transition to the new Act say the old Act applies where the relevant event fell on or before 31 March 2026, that the return for financial year 2025-26 is filed under the 1961 Act, and that corrections for those periods must use the old forms even when they are filed after 1 April 2026. As a result, a remittance in February 2026 produces a Form 27D, a remittance in May 2026 produces a Form 133, and a client who remitted in both months will hold one of each.
This matters for the return now being prepared. Circular 07/2026 extended the audit report date to 21 October 2026 and the return date to 21 November 2026 for companies, audited non-company taxpayers and partners of audited firms, although transfer pricing cases keep their own dates. Every TCS credit claimed in those returns comes from collections made under the old law, so Form 27D is the document the CA has to check.
How Form 27D supports the client's TCS credit
TCS is not a final tax. It is an advance credit that the client sets against the tax due on their own return, and any excess comes back as a refund. For financial year 2025-26, banks collected TCS of 20 per cent on investment remittances above ₹10 lakh in the year, while education and medical remittances attracted a lower rate, according to the rate tables authorised dealer banks published.
For example, a client who remitted ₹25 lakh in January 2026 to buy shares abroad, with no other remittance that year, would have paid TCS of ₹3 lakh, which is 20 per cent of the ₹15 lakh above the threshold. That amount should appear on the bank's Form 27D for the January to March 2026 quarter, against the client's PAN, and in the client's Form 26AS and Annual Information Statement. If all three agree, the ₹3 lakh goes into the TCS schedule of the return and reduces the tax payable or adds to the refund.
Family remittances need extra care. The certificate is issued in the name of the person whose PAN the bank recorded, and the credit normally follows that PAN. Where a spouse or parent funded the transfer, the CA should confirm whose return will claim it and settle the clubbing of income and gift tax questions at the same time.
Where Form 27D and the tax statements disagree
The certificate is only as good as the quarterly statement behind it. TRACES generates Form 27D only for processed statements and valid PANs, so a bank that filed late, quoted a wrong PAN or reported a remittance in the wrong quarter will leave the client with a credit that does not show in Form 26AS. The client cannot fix this alone. The bank has to file a correction statement, and the transition FAQs say corrections for financial year 2025-26 can be filed within two years from the end of the tax year in which the original statement was due.
Timing at the year end is the other trap. A remittance initiated in the last days of March 2026 may have been completed and reported in April, which would place it under the new law and on a Form 133 instead. The client's own record of the remittance date and the bank's certificate should tell the same story. Where they differ, the CA should ask the bank which statement carried the collection before the return goes in, rather than claim the credit in the wrong year.
What advisors should do before 21 November
The practical work is short, and most of it fits into a single call with each affected client. These are the steps in the order they are usually done.
- Ask each client with audited accounts for every Form 27D issued for financial year 2025-26, including certificates from car dealers and tour operators as well as banks.
- Match each certificate against Form 26AS and the Annual Information Statement, quarter by quarter and PAN by PAN.
- Where a credit is missing or wrong, write to the collector and ask for a correction statement, keeping a copy of the remittance advice.
- Set aside collections made after 1 April 2026, which belong on Form 133 and next year's return.
- Keep the certificates in the client's tax file, because the department may ask for them later.
Advisors who introduce eligible clients through Raveum's partner page will recognise the pattern, because each investment remittance above the threshold produces a certificate that has to be tracked. Raveum handles KYC, agreements and US tax forms for the investment itself, while the client's Indian tax position, including the TCS credit, stays with the client and their CA.
The arrival of Form 133 made it tempting to treat Form 27D as a closed chapter. For this November's returns the opposite is true, because every TCS credit in them still rests on the old certificate and the statement behind it. An advisor who checks those documents now, while banks still have time to correct them, does more for the client's refund than any complaint after filing. The rules for both years are set out in our guide to TCS on foreign remittance.
Frequently asked questions
What is Form 27D in income tax?
Form 27D is the TCS certificate issued under section 206C of the Income-tax Act, 1961. It shows the tax a collector, such as a remitting bank, collected from a client and paid to the government in a quarter. It covers collections made up to 31 March 2026, and the client uses it to claim credit in the return.
Has Form 27D been replaced by Form 133?
Yes, for collections from 1 April 2026. Form 133 under Rule 215 of the Income-tax Rules, 2026 is now the TCS certificate. Form 27D still applies to tax collected on or before 31 March 2026, so returns for financial year 2025-26 and any corrections for that period continue to rely on it.
When should a collector issue Form 27D?
Form 27D is issued every quarter, within 15 days of the due date for filing the quarterly TCS statement on Form 27EQ, under Rule 37D. The certificate is downloaded from the TRACES portal and signed by the collector. Certificates for the last quarter of financial year 2025-26 should already be with clients.
How can a client download or check Form 27D?
Only the collector can download Form 27D from TRACES, so the client has to ask the bank or seller for it. The client can check the same credit independently in Form 26AS and the Annual Information Statement on the income tax e-filing portal. Matching the two before filing avoids most refund delays.
What if the TCS on Form 27D does not appear in Form 26AS?
The client should contact the collector and ask it to check its quarterly statement for a wrong PAN, a wrong amount or a missing entry. Only the collector can file a correction statement. For financial year 2025-26, corrections must still be filed under the old Act and with its form numbers.
Does TCS make a foreign investment more expensive for a client?
TCS is not an extra tax, because it is credited against the client's own tax liability or refunded. It does tie up money until the return is processed, which affects cash flow. Foreign investments also carry their own risks, including loss of capital, illiquidity and currency movements, which the client should weigh separately with an advisor.
This article is for general education and is not tax, legal or investment advice. Rules change and depend on individual circumstances. All investing involves risk, including loss of capital, illiquidity and currency movements. Offerings on Raveum are available to eligible investors only and are not open to the general public.
