As we know, every TDS deductor is required to file a statement containing the details of the deductees in order to ensure that proper credit of the tax deducted is given to them. This statement is commonly referred to as a TDS return.
Under the Income-tax Act, 1961, there were primarily four types of TDS returns, namely Forms 24Q, 26Q, 27Q, and 27EQ, each applicable to different categories of payments such as salary, non-salary payments, payments to non-residents, and tax collected at source.
With the introduction of the Income Tax Act, 2025, which is set to come into force shortly (i.e. 1st April 2026), the provisions relating to TDS compliance have been consolidated and rationalized. However, from a practical and procedural standpoint, there is no significant change in the return filing mechanism.
The key change lies in the renumbering of forms. The four existing TDS returns continue to exist in substance, but they have been assigned new form numbers under the new Act. For instance, Form 24Q has been replaced with a newly designated form (e.g., Form 138). Similar renumbering applies to the other forms as well. The below table provides a comparative overview of the new forms vis-à-vis the old forms.
| Sl. No. | Particulars | Old Forms | New Form |
| Governed by Income Tax Act 1961 | Governed by Income Tax Act 2025 | ||
| 1 | Salary TDS Return | Form 24Q | Form 138 |
| 2 | Non-salary TDS Return | Form 26Q | Form 140 |
| 3 | Non-Resident TDS Return | Form 27Q | Form 144 |
| 4 | TCS Return | 27EQ | Form 143 |
In addition to the regular quarterly TDS returns, the law also prescribed certain specified transactions where the deductor was required to furnish a TDS-cum-challan statement instead of the standard quarterly return. These statements were transaction-specific and applicable in particular cases. The relevant forms under the Income-tax Act, 1961 were as follows:
(i) Form 26QB — TDS on purchase of immovable property (Section 194-IA)
(ii) Form 26QC — TDS on payment of rent by an individual or HUF (Section 194-IB)
(iii) Form 26QD — TDS on payments by individuals/HUFs to contractors and professionals (Section 194M)
(iv) Form 26QE — TDS on transfer of virtual digital assets (Section 194S)
A key change under the Income Tax Act, 2025 is the consolidation of all these TDS-cum-challan statements into a single unified form, namely Form 141. This change simplifies compliance by replacing multiple transaction-based forms with a single reporting framework.
Transition Period:
Since the return for the fourth quarter falls within the transition phase from the Old Income Tax Act to the new Income Tax Act, a practical question arises as to which forms should be used for compliance. To address this concern, the Central Board of Direct Taxes (CBDT) has issued FAQs providing much-needed clarity.
As per the FAQs, all four existing TDS return forms under the Income-tax Act, 1961 will continue to remain applicable for the purpose of filing the fourth quarter returns. The newly introduced forms under the Income Tax Act, 2025 shall be applicable from the filing of returns for the first quarter of Financial Year 2026–27 onwards.
In conclusion, while the new Income Tax Act introduces structural changes such as renumbering of forms and consolidation of TDS-cum-challan statements, the overall compliance framework remains largely unchanged.
Author Bio
Useful info