Summary: For tax year 2026-27, the quarter ended 30 September 2026 is the second quarterly TDS reporting period under the Income-tax Act, 2025 and Income-tax Rules, 2026. The Income Tax Department’s current form manuals specify 31 October 2026 as the ordinary filing date for Form 138 (the successor to salary Form 24Q), Form 140 (the successor to resident non-salary Form 26Q) and Form 144 (the successor to non-resident non-salary Form 27Q). The change is not merely cosmetic: deductors must select the correct Act and tax year, use current form numbers and codes, match each tax deduction to the right challan, validate the return-preparation utility and file the correct regular or correction statement. The quarterly statement is distinct from the monthly obligation to deposit TDS and from transaction-specific Form 141. A successful upload also must not be mistaken for an accepted statement; portal rejection requires rectification and resubmission. This article identifies the filing population, evidence required, practical checks and tax-credit consequences without treating the deadline as an extension of any other tax or GST compliance.
- Why 31 October 2026 Matters for TDS Deductors
- Correct Quarterly Statement for Each Payment Category
- Do not confuse quarterly forms with Form 141
- Income-tax Act 2025 Transition: Choose the Governing Law First
- Reconcile the Deductor Ledger, Challans and Payee Data
- Separate ordinary TDS from correction and special-rate cases
- How the Official Electronic Filing Process Works
- Salary Form 138: Payroll-Specific Checks
- Resident Non-Salary Form 140: Vendor-Level Controls
- Non-Resident Form 144: More Than a PAN Check
- Late Filing, Correction Statements and Evidence Retention
- Practical October 2026 Filing Sequence
- Official Sources and Verification Basis
- Frequently Asked Questions
- 1. What is the Q2 TDS statement due date for tax year 2026-27?
- 2. Which form replaces old Form 24Q?
- 3. Which form replaces old Form 26Q?
- 4. Which form replaces old Form 27Q?
- 5. Is depositing TDS enough without filing the quarterly statement?
- 6. Does successful upload mean the return has been accepted?
- 7. Can Form 141 transactions simply be included in Form 140 or 144?
- Key Takeaways
Why 31 October 2026 Matters for TDS Deductors
The July–September 2026 quarter is the second quarter of tax year 2026-27, the first full tax year governed by the Income-tax Act, 2025. The Department has issued current user manuals for Forms 138, 140 and 144, each expressly showing 31 October as the Q2 due date. A deductor should therefore use the forms prescribed for the tax year, not simply reuse the previous year’s file naming or legacy return category. The reporting obligation concerns taxes deducted from salary, resident non-salary payments and specified non-resident payments; it is not a substitute for depositing those taxes on time.
The new architecture is discussed in TaxGuru’s Income-tax Act, 2025 TDS compliance guide. That reference is useful for understanding the old-to-new section map, but the authoritative filing dates and form procedures in this article are drawn from the Income Tax Department’s own current manuals. Where a special transaction is reported by a challan-cum-statement rather than a quarterly TAN return, it must be kept outside the wrong statement population.
Correct Quarterly Statement for Each Payment Category
| 2026 form | Legacy equivalent | Principal coverage | Q2 2026 deadline |
|---|---|---|---|
| Form 138 | Form 24Q | Salary, pension and specified bank reporting | 31 October 2026 |
| Form 140 | Form 26Q | Resident non-salary payments such as professional fees, rent, commission | 31 October 2026 |
| Form 144 | Form 27Q | Non-salary payments to non-residents where quarterly TAN reporting applies | 31 October 2026 |
| Form 143 | Form 27EQ | TCS quarterly statement; separate collection regime | 31 October 2026 |
Form 138 covers the salary-side TDS statement and specified bank reporting described in the Department’s manual. Form 140 covers non-salary payments to resident deductees, including typical business expenditure such as rent, professional services, brokerage and contractor payments where deduction is required. Form 144 applies to non-resident non-salary payments subject to the regular quarterly statement mechanism. Form 143 is included in the comparison because collectors often share a compliance team with deductors, but it reports tax collected at source and should not be merged into a TDS return.
Do not confuse quarterly forms with Form 141
Form 141 is the consolidated challan-cum-statement for specified transactions under sections 393(1) and 393(2). It has a different payment and filing timetable, generally within one month from the end of the month of deduction, and uses a PAN-login workflow. Transactions appropriately reportable there must not be duplicated as ordinary TAN-based quarterly entries. For example, a covered resident individual purchasing property from a non-resident seller from 1 October 2026 may fall under Schedule E of Form 141; that is a separate transaction-based procedure rather than a reason to amend the July–September Form 144 population retrospectively.
Income-tax Act 2025 Transition: Choose the Governing Law First
The Income Tax Department’s transition FAQs say the governing deduction law generally follows the earlier of credit or payment. Where that event arose on or before 31 March 2026, the Income-tax Act, 1961 remains relevant; where it arose from 1 April 2026, the Income-tax Act, 2025 governs. The new Act reorganises salary deduction under section 392 and many other deduction obligations under section 393. Incorrectly quoting a legacy section for a current-year transaction can lead to processing or classification issues even where the monetary rate and threshold are unchanged.
The quarter under review falls wholly after 1 April 2026, but opening balances and late payments from earlier periods may still create cross-year accounting entries. Payroll and accounts teams should not classify a payment solely by the date on which cash left the bank. They should first establish when the legal deduction event occurred and whether a current-period entry belongs in the new Act’s return. The 2026 TDS and TCS changes provide additional context for the mapping, while the Department’s portal should control the actual code selected for filing.
Reconcile the Deductor Ledger, Challans and Payee Data
The strongest control is a transaction-level register covering date of credit, date of payment, date and amount of tax deducted, applicable statutory category, deductee PAN, residential status, certificate details and challan allocation. A trial balance total alone is insufficient. It may combine deductible and non-deductible transactions, GST components, reimbursements, reversals and earlier-period adjustments. Each line in the statement must be traceable to a ledger entry and the tax deposited against it.
Check the tax year, quarter, TAN, deductor legal name, PAN and applicable return type before importing records into the return-preparation utility. Reconcile challan serial number, bank identification information, date, tax, interest and fee with the payment records. A challan deposited late does not disappear from reporting merely because interest may be payable. Conversely, a challan should not be claimed against an unrelated period simply to make totals match.
Separate ordinary TDS from correction and special-rate cases
Maintain separate working papers for nil or lower deduction certificates, payments subject to higher withholding for PAN-related reasons, reimbursements where tax treatment requires analysis, and non-resident payments requiring treaty or chargeability review. A lower or nil certificate is not a general authorisation to change rates for every payment to the same supplier; confirm the covered income, period, rate and certificate number. For non-residents, distinguish the taxability of the underlying sum from the reporting format. The return is an information statement and does not itself resolve a disputed chargeability question.
How the Official Electronic Filing Process Works
The Department’s Form 140 and Form 144 manuals describe preparation through the updated Return Preparation Utility, generation of a validated FVU file and uploading the zipped FVU through the TAN login. The filer selects the Income-tax Act, 2025 category, applicable tax year, quarter, form and upload type. The precise utility version matters: a file created with an outdated validation package may be rejected even when the spreadsheet or payroll data are otherwise complete.
After uploading, the user proceeds to electronic verification by the applicable method. The portal then validates the statement and communicates acceptance or rejection. An acknowledgement of upload and a statement finally accepted for processing are different stages. The manuals specifically identify wrong tax year, TAN mismatch, outdated FVU version, duplicate filing and confusion between regular and correction files as examples of rejection causes. If rejected, the deductor must correct the file and submit a valid replacement rather than treating the first upload as completion.
| Control stage | Document or check | Reason it matters |
|---|---|---|
| Before utility | Deductor master, PANs, resident status, payment classification | Prevents wrong form and incorrect payee mapping |
| Tax deposit | Challans and allocation ledger | Links deductions to amounts paid |
| Before upload | Current RPU/FVU version, quarter, tax year, TAN | Avoids technical rejection |
| After e-verification | Portal status and acknowledgement | Distinguishes submitted from accepted |
| After processing | Deductee tax-credit review and correction register | Identifies mismatches requiring amendment |
Salary Form 138: Payroll-Specific Checks
Salary reporting should reconcile employee-wise taxable salary, exemptions, deductions and the monthly withholding actually made. Changes in salary, joining or leaving dates, arrears, bonus payments and prior-employer information can materially affect the annual computation. The quarterly return should be built from the approved payroll register and not from bank disbursement alone. The Department’s Form 138 manual also describes specified reporting by banks in relation to pension or certain senior-citizen income; those entities must review their own category rather than assuming every Form 138 filer is an ordinary employer.
An employee PAN typo can affect tax-credit visibility and lead to payroll queries even where the employer has deposited the correct aggregate tax. Reconcile the employee master, Form 138 particulars, deductions shown on payslips and challan allocations. Where the employer discovers an error after acceptance, the appropriate correction-statement process should be followed and the employee informed of the revised credit timeline. This is a data-integrity control, not merely a portal filing formality.
Resident Non-Salary Form 140: Vendor-Level Controls
Accounts payable should test each relevant vendor payment against the appropriate section 393 category, including the transaction’s nature, threshold and time of deduction. A vendor may receive rent, professional fees and reimbursements under different contracts; combining them under a single code can produce an inaccurate return. Review credit notes, cancellations, year-end provisions, reversed accruals and payments to parties with similar names but different PANs. Where tax was deducted on an amount later reversed, document the accounting and reporting treatment rather than silently netting the entry without evidence.
The Department identifies Form 140 as the successor to Form 26Q and expressly specifies 31 October for Q2. The 2025 Act’s reorganised numbering does not eliminate the need to distinguish resident and non-resident payees. If a foreign supplier is non-resident for tax purposes, simply recording an Indian address or paying into an Indian bank account does not make Form 140 the correct statement. The legal classification and underlying withholding analysis should be reviewed before filing.
Non-Resident Form 144: More Than a PAN Check
Form 144 is the regular quarterly statement for non-salary payments to non-residents. The preparer should review the nature of the income, treaty documentation where relied upon, certificate particulars, grossing-up arrangements, surcharge and cess where applicable, and the difference between income taxable in India and amounts outside the charge. The return should be consistent with the payment file and any relevant remittance information. A Form 145 or 146 remittance record does not automatically replace the quarterly TDS statement where Form 144 is required.
The official Form 144 manual follows the same broad utility-and-FVU process as Form 140 and lists 31 October as the Q2 filing date. Because non-resident payments are fact-sensitive, reviewers should record the basis for the rate applied rather than copy the rate used for another vendor. A certificate for one payment or period must not be extrapolated to a different contract. Where the seller or service provider has multiple taxable streams, maintain a clear schedule of how each amount was reported.
Late Filing, Correction Statements and Evidence Retention
Late or incorrect statements can expose a deductor to statutory fees, penalties or other consequences under the applicable provisions, apart from delayed credit for the deductee. The Department’s current manuals warn of late-filing consequences. The amount of any fee or penalty must be computed by reference to the governing law, delay and facts; do not assume that depositing the TDS cures a separate failure to report. Interest on delayed deduction or deposit is a different issue from the return-filing obligation.
A sound closing file contains the signed or approved reconciliation, final FVU version, challans, payment confirmation, portal acknowledgement, acceptance status, corrections and correspondence with deductees. If the portal rejects the return, preserve the rejection reason and resubmission trail. The control owner should confirm acceptance before marking the 31 October task closed. A correction should be supported by a version-controlled difference report identifying what changed, why it changed and who authorised the amendment.
Practical October 2026 Filing Sequence
By mid-October, the tax team should freeze the July–September deduction register, obtain payroll and vendor sign-offs, and check unresolved challan mismatches. In the following week, it should prepare the correct form files, run utility validation and review exception reports. The last stage is uploading, electronic verification, checking acceptance and archiving evidence. This is a workflow suggestion, not a separate statutory due date. Where a notice, special approval or changed portal requirement applies, follow that specific requirement rather than a generic internal calendar.
Official Sources and Verification Basis
- Income Tax Department, Form 138 User Manual (successor to Form 24Q), current portal version reviewed 15 October 2026.
- Income Tax Department, Form 140 User Manual (successor to Form 26Q), current portal version reviewed 15 October 2026.
- Income Tax Department, Form 144 User Manual (successor to Form 27Q), current portal version reviewed 15 October 2026.
- Income Tax Department, TDS Compliance FAQs and ITNS 281N challan guidance for tax year 2026-27.
Frequently Asked Questions
1. What is the Q2 TDS statement due date for tax year 2026-27?
The Income Tax Department’s current manuals specify 31 October 2026 for the July–September quarter for Forms 138, 140 and 144.
2. Which form replaces old Form 24Q?
Form 138 is the current quarterly statement for salary, pension and specified bank reporting under the 2025 Act framework.
3. Which form replaces old Form 26Q?
Form 140 covers applicable non-salary deductions on payments to resident deductees.
4. Which form replaces old Form 27Q?
Form 144 covers applicable regular quarterly reporting of non-salary payments to non-residents.
5. Is depositing TDS enough without filing the quarterly statement?
No. Payment and the applicable reporting statement are distinct obligations; each must be complied with within its own prescribed timetable.
6. Does successful upload mean the return has been accepted?
Not necessarily. Check the portal processing status; an invalid FVU or mismatch can cause rejection and require resubmission.
7. Can Form 141 transactions simply be included in Form 140 or 144?
No. Identify the prescribed transaction-specific challan-cum-statement route and avoid duplicating or misclassifying such transactions in regular TAN statements.
Key Takeaways
- Forms 138, 140 and 144 have an ordinary Q2 due date of 31 October 2026.
- Use tax year 2026-27 and the correct Income-tax Act, 2025 form and transaction code.
- Reconcile tax deductions, PANs, challans, certificates and payment classification before FVU validation.
- Confirm the portal has accepted the statement, not merely received an upload.
- Keep Form 141 transaction-based compliance separate from quarterly TAN returns.
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Disclaimer: This article provides general educational information on the Income-tax Act, 2025 and Income-tax Rules, 2026 as reviewed on 15 October 2026. It is not a filing instruction for any particular deductor, a legal opinion or a substitute for examining the statute, applicable notification, tax year, transaction, certificates and live Income Tax Department portal. Due dates and technical procedures may be altered by competent authorities. Readers should obtain appropriate professional advice and independently confirm applicability, rate, payment, reporting and acceptance status. TaxGuru accepts no responsibility for errors, omissions, subsequent legal or portal changes, rejected filings, tax demands, penalties, losses or decisions made in reliance on this material.
