TDS Returns under the Income Tax Act, 2025: Forms, Due Dates and Filing Procedure

The Income-tax Act, 2025 came into force on 1 April 2026 and governs all deductions of tax at source where the earlier of credit or payment falls on or after that date. The substance of the TDS regime has not been rewritten; what has changed is the statutory architecture, the form numbering and, in one instance, a due date. The quarterly TDS statement, long filed under section 200(3) of the Income-tax Act, 1961 read with Rule 31A of the Income-tax Rules, 1962, is now furnished under section 397(3)(b) of the Income-tax Act, 2025 read with Rule 219 of the Income-tax Rules, 2026. The first statement filed entirely under the new framework was that for the quarter ended 30 June 2026, due on 31 July 2026. This article sets out the statutory basis, the form mapping, the due dates, the deposit and filing procedure, the certificate obligations and the consequences of default, drawing on the guidance notes issued by the Income-tax Department for the new forms.

Statutory framework

The Income-tax Act, 2025 consolidates the deduction provisions that were scattered across sections 192 to 196D of the 1961 Act. Section 392 houses TDS on salary, replacing section 192. Section 393 consolidates the entire non-salary TDS regime into a single provision with a schedule of payment types — interest, commission, brokerage, rent, contractual payments, professional fees and the rest — each identified by a payment code rather than a standalone section number. Section 395 deals with certificates for deduction at lower or nil rates, replacing section 197. Section 397 is the compliance provision: it covers TAN, the furnishing of quarterly statements under sub-section (3)(b), and related reporting obligations. Section 400 deals, inter alia, with tax on virtual digital asset transactions, with sub-section (2) casting a reporting obligation on exchanges.

The practical consequence for deductors is that the section codes cited in returns and internal masters for over two decades — 192, 194C, 194H, 194J and so on — do not exist for transactions on or after 1 April 2026. The Department has indicated that statements citing old section codes for post-transition transactions will fail validation at upload.

Form mapping: old to new

The Income-tax Rules, 2026 carry a fully renumbered set of prescribed forms. The mapping every deductor should keep at hand is as follows:

The Department's guidance note for Form No. 140 records the lineage expressly: earlier Form 26Q, earlier section 200(3), earlier Rule 31A, now Form 140 under section 397(3)(b) and Rule 219. Corresponding notes exist for Forms 138, 143 and 144.

A critical transition rule follows from this mapping. The old forms have not been withdrawn; they remain the correct forms for statements — original, belated or correction — relating to transactions up to 31 March 2026. A correction statement for Q4 of FY 2025-26 filed today goes on Form 26Q; the Q1 statement for tax year 2026-27 goes on Form 140. A single deductor will legitimately file on both series in the same calendar year, and the two must not be mixed.

Due dates for quarterly statements

For TDS statements (Forms 138, 140 and 144), the quarterly calendar is unchanged in substance:

For TCS, however, the calendar has moved. Under the erstwhile Rule 31AA, Form 27EQ was due on 15 July, 15 October, 15 January and 15 May for the four quarters. Under the Income-tax Rules, 2026, the TCS statement in Form 143 follows the same calendar as the TDS statements and is due on 31 July, 31 October, 31 January and 31 May. The change is an extension, so no default arises from continuing to work to the old dates; the more likely error runs the other way — a collector whose reminder system still fires on the 15th may believe a default has occurred where none has. Compliance calendars should be updated to align all four statements to the common dates above.

Deposit of tax before filing

The statement can only be filed once the deducted tax stands deposited. Deposit timelines are prescribed under Rule 218 of the Income-tax Rules, 2026, which the Department has confirmed corresponds to Rule 30 of the 1962 Rules and retains the same timelines without any policy change: the 7th of the month following deduction for non-government deductors, with the March deduction due by 30 April. Government deductors remitting by book adjustment must deposit on the same day as deduction; the 7th-of-the-month rule applies to government deductors only where payment is made by challan. Delay in deposit attracts interest at 1.5 per cent per month, computed from the date of deduction (not from the 7th) to the date of actual payment. The challan particulars — BSR code, date of deposit, challan serial number and minor head — feed directly into Part B of the quarterly statement, so reconciliation of challans against the deduction register should precede return preparation.

How to file: the process flow

The Department's guidance note for Form No. 140 sets out the filing process, which applies mutatis mutandis to Forms 138, 143 and 144:

1. Deduct tax at the time of payment or credit under the applicable provision (section 392 or 393, with the correct payment code).
2. Deposit the tax to the credit of the Central Government within the time prescribed under Rule 218.
3. Prepare the quarterly statement using the Return Preparation Utility (RPU) available from the TIN portal.
4. Validate the file using the File Validation Utility (FVU); an error-free validation generates a .fvu file.
5. Upload the .fvu file on the e-filing portal, or submit it physically at a TIN Facilitation Centre.
6. On successful submission, the data is inwarded at CPC-TDS and the statement is processed under the provisions of the Income-tax Act, 2025.

The documents required are limited but non-negotiable: copies of challans deposited to the credit of the Central Government, and PAN details of every deductee. The annexure to Form 140 captures deductee-wise particulars — PAN, name, section/payment code, amount paid or credited, dates of payment and deduction, tax deducted and deposited, rate applied, reason for non-deduction or lower or higher deduction, the certificate number where a section 395 certificate operates, and the UIN of Form No. 121 where applicable. Form 140 carries a single annexure format filed identically across all four quarters.

Processing at CPC-TDS results either in a statement without default or one with defaults. Where defaults are intimated — short deduction, short payment, interest, fee or PAN errors — the deductor is required to pay the default amount where applicable and file a correction statement. A filed statement cannot be edited directly; corrections travel through the correction-statement route after the original is processed.

Certificates and credit to the deductee

Certificate issuance is tied to the filing due date. Form 131 (non-salary TDS certificate, successor to Form 16A) is generated through TRACES on the strength of the processed Form 140 data and must be issued to each deductee quarterly within 15 days from the due date of filing — that is, by 15 August, 15 November, 15 February and 15 June. Form 130 (salary certificate, successor to Form 16) follows Form 138, and Form 133 (TCS certificate, successor to Form 27D) follows Form 143 on the same 15-day principle. Certificates must be generated from TRACES; self-generated formats are not valid. Once the statement is processed, the deducted amounts reflect in the deductee's Form No. 168 and the Annual Information Statement, enabling credit in the deductee's return of income. For tax year 2026-27, a certificate issued in the old format is not a valid certificate.

Consequences of default

Delay in furnishing the quarterly statement attracts a fee under section 427 of the Income-tax Act, 2025 — the successor to section 234E — at ₹200 per day of default, capped at the amount of tax deducted or collected reported in the statement. The fee must be paid before the belated statement is furnished. The Department's FAQs for the new forms further reference penal proceedings under section 461 and section 465(2)(g) of the 2025 Act, where applicable, replacing the section 271H framework. Delayed deposit of deducted tax separately attracts interest at 1.5 per cent per month from the date of deduction to the date of actual payment. Statements relating to periods up to 31 March 2026 continue to be governed by sections 234E and 271H of the 1961 Act.

What has changed inside the forms

Beyond renumbering, the Department's guidance notes describe qualitative changes. Outdated fields have been replaced — the Token Number gives way to a Return Receipt Number, and the TAN Registration Number field has been deleted. Surcharge and cess details stand consolidated under the challan or book-adjustment entries. Across all forms, "Assessment Year", "Financial Year" and "Previous Year" have been replaced with "Tax Year", grouped name-address-PAN fields have been separated into discrete boxes for system-friendly e-filing, and section, clause and schedule references have been aligned to the 2025 Act. The revised forms are designed as smart forms, with auto-population from the deductor's TRACES profile, real-time validations, drop-downs and date pickers, API integration and checkbox-based verification.

Compliance checklist for deductors

Before the next quarterly statement is uploaded, a deductor should verify five things: that the accounting system's section master has been migrated from the 1961-Act codes to the section 392/393 payment codes; that the return is being prepared on the correct form series for the period concerned; that all challans for the quarter are deposited and reconciled; that valid PANs are on record for every deductee, since PAN errors surface as processing defaults; and that certificate templates and internal calendars reflect Forms 130, 131 and 133 and the 15-day issuance timelines. The TDS law under the Income-tax Act, 2025 is, in substance, the law deductors already know — but a return prepared on the old numbers will not clear validation, and the transition discipline lies entirely in the detail.

Sources: Income-tax Act, 2025; Income-tax Rules, 2026 (Rules 218 and 219); guidance notes and FAQs issued by the Income-tax Department for Form Nos. 138, 140, 143 and 144 (incometaxindia.gov.in); TDS Compliance FAQs, Income Tax e-filing portal (incometax.gov.in).

Disclaimer: This article is for general informational purposes only and does not constitute professional advice. Readers should refer to the relevant provisions of the Income-tax Act, 2025, the Income-tax Rules, 2026 and applicable notifications, and consult a qualified professional before acting on any information contained herein. The author accepts no responsibility for any loss arising from reliance on this article.