CBDT turns its attention to Form 15CB – and to the Accountants who sign it
On 18 August 2026, the Central Board of Direct Taxes announced a nationwide verification exercise into suspicious outward foreign remittances. The exercise covers approximately 394 entities, of which 117 are located in districts along India’s land borders, and – for the first time stated so plainly in a press release – 36 professionals who issued Form 15CB certificates.
The trail began elsewhere. A search operation on a group of fictitious charitable trusts, engaged in providing accommodation entries against bogus donations, exposed a wider network of entities remitting funds abroad. The Department then ran that network against its outward remittance data. What emerged was a set of patterns it has evidently now templatised: remitters who were either non-filers or filers reporting turnovers bearing no correlation to the sums leaving the country; stated purposes clustered around freight, import of software and import of consulting services; and entities that could not be found at the addresses they had declared.
The second finding is the one the profession should read carefully. A disproportionately large number of Form 15CB certificates were traced to a relatively small group of professionals, with the remitted funds being received by a clustered group of overseas entities. That is a data-analytics signature rather than a case-by-case suspicion, and it means concentration itself has become a selection parameter. A Chartered Accountant with high 15CB volumes routed to a narrow set of payees is now visible to the system regardless of the merits of any individual certificate.
The legal standard the Department invokes is not new. Form 15CB, read with Rule 37BB of the Income-tax Rules, 1962 – corresponding to Form 146 read with Rule 220 of the Income-tax Rules, 2026 – requires the certifying Accountant to determine taxability with reference to the books of account and other relevant documents.
For remitters, the practical consequence is that the burden has shifted forward. A remittance file that consists only of an invoice and a signed certificate will not survive scrutiny where quantum and declared turnover diverge. The defensible file carries the underlying agreement, the invoice, the tax residency certificate, Form 10F, a no-permanent-establishment declaration where the treaty position depends on it, and a contemporaneous note recording why the size of the remittance is consistent with the remitter’s own books. For the certifying professional, the same file is the only meaningful protection, and it must be built before the certificate is issued rather than reconstructed after a notice arrives.
