CA Forums

Forms 15G and 15H were self-declaration forms submitted to banks and financial institutions to prevent Tax Deducted at Source (TDS) on income such as bank interest, dividends, and insurance payouts. Effective April 1, 2026, both forms have been replaced and merged into a single Form 121 under the Income Tax Act, 2025.

Form 121 is almost same as Forms 15G/H. Only the number of the forms has been changed to 121. This form also has almost the same information which Forms 15G/H had. Only the placement of the items has been changed. Of course, there is one important change. Now you have to provide information about the last two income tax returns filed by you, i.e., their acknowledgement numbers and the income reported by you in those returns. This data was not being asked in Forms 15G/H.

COMBINING 15G/H INTO ONE FORM –

The Income Tax Deptt. is patting its own back since they have now combined Forms 15G/H into a single form and, thus, done a big favour to the Indian tax-payers. What a great innovation! Could Albert Einstein ever do such a great job? The Indian income-tax payers always wondered that when they wanted to declare a simple thing that their income is below taxable limit and therefore IT at source should not be imposed on their payments, where did their age come into picture? After troubling us unnecessarily for about 80 years by differentiating between 15G/H, has better sense now prevailed on the IT Deptt.? Well, yes and no. True, that now there is only one form rather than two, but in this Form 121 also, there is a column in which you have to declare whether you are above 60. Also, under ‘Declaration’ in Part A, 1 out of 5 clauses, is not applicable to those above 60. What can I say on this? Old habits die hard! And sometimes they don’t die at all.

INTRODUCTION OF TAX YEAR –

All of us do all our financial calculations and budgeting on the basis of financial year. But not our great IT Deptt. They add 1 to the financial year and talk of a strange thing - ‘Assessment year’. They never utter the word - ‘Financial year’. They avoid it like plague. And when it becomes unavoidable to talk about it, they call it - ‘Previous Year’! However, now they have done another great invention and they are proudly announcing that they are having great mercy on the tax payers and doing away with both ‘Assessment Year’ and ‘Previous Year’. Now they have coined a still new word - ‘Tax Year’. Can I ask them why they cannot use simple and beautiful ‘Financial Year’ and what was the need of this new word? Can I ask them how ‘Tax Year’ is different from ‘Financial Year’? No, never. They are experts and I am a layman. How can I even think of doing such an impudence (धृष्टता)! May be, after another period of 100 years they realize that there was no need of ‘Tax Year’ and start using ‘Financial Year’. Will they again pat their back on this enlightenment? Of course, yes! Why not?

CLAUSES IN DECLARATION –

Under Declaration of Part A, there are a total of 5 clauses. Out of these, the clauses (iii) and (iv) are really interesting. Both of these clauses are applicable for those below 60. But Clause (iv) is not applicable to those above 60. For them, only clause (iii) is applicable. Want to know what these clauses say? Well, here it is:

Clause (iii) says – “Tax on my income for this financial year will be nil”. (Sorry, tax year!)

Clause (iv) says – “My income for this financial year will not be taxable”. (Again sorry!)

Can you find out the difference between these two clauses? In spite of my best efforts, at least I could not do it. Maybe I am too dumb and I cannot fathom the intelligence of the IT Deptt.

Even before we wonder about all this, is any of these two clauses really required? The tax payer has already specified his estimated total income of the current financial year in the main section of Part A. Anybody can immediately conclude whether his income will be taxable.

NO IDENTIFIER TO RECOGNIZE THE INVESTMENT –

Form 121 lacks a means of identification for specific investments. Unlike Forms 15G/H, which included a field for the "Identification Number of relevant Investment / Account," Form 121 provides no such space.

This creates an issue when an individual holds multiple types of investments with the same bank. For example, I have a few fixed deposits, investment under Senior Citizen Savings Scheme (SCSS), and RBI Bonds (FRSB 2020) all through ICICI Bank. Each of these investments has a different person responsible for the payment of interest obviously with different TANs.

Previously, I used to submit three 15H forms, specifying the Fixed Deposit Receipt Numbers, SCSS Account Numbers, and Bond Ledger Account Number/Folio Number respectively. This allowed the bank to clearly identify the purpose of each form. Without these identifiers in Form 121, banks will face considerable difficulty in directing forms to the correct departments for processing.

My wife has purchased RBI Bonds through HDFC Bank. She has no other investment in HDFC Bank. She submitted her Form 121 to the bank. The next day she received a phone call from the bank to furnish her Bond Ledger Account since they weren’t able to link her form with her investment without it.

DUPLICATION OF DATA –

A lot of the information which Part A contains has been duplicated in Part B in Form 121. To be specific, the person filling Part B has been asked to duplicate following items:

1. Name of the declarant
2. Permanent Account Number of the declarant
3. Address of the declarant
4. Email id of the declarant
5. Contact number of the declarant
6. Tax Year (Financial Year)
7. Estimated income for which this declaration is being made
8. Estimated total income of the tax year of the declarant
9. Aggregate amount of income for which declaration is made during the tax year

It is really amusing to notice that Form 121 carefully specifies which column of Part B can/should be copied from which column of Part A.

Anyway, due to this extensive duplication, Form 121 will require at least two pages whereas Forms 15G/H could easily be accommodated in a single page. It means that the consumption of paper will increase by thousands of tons. Additionally, they are asking the PAN’s to be written many times. The tax payer’s PAN is to be specified at 3 places and the name and PAN of the person receiving the form are to be filled at 2 places. How are the name and PAN of the receiving person even relevant? They act on the behalf of their organizations and not in their personal capacity.

DATE OF BIRTH –

There is also a serious oversight in the form. Date of Birth/Incorporation is to be specified in column 11 in Part B by the person to whom the form has been submitted. However, there is no mention of this in Part A. How will he get this data?

OTHER 121 FORMS FILED EARLIER –

While filing Form 121, you also have to specify the relevant information about other such forms filed by you, if any, for the same financial year. This information was to be provided previously in Forms 15G/H also and there is no change in it. However, this is very complicated and it should have been deleted in Form 121 if they really wanted any simplicity or improvement in the system. A detailed discussion is required on this. Let us take the following example:

I have fixed deposits in 4 banks. The interest amounts expected to be paid to me by these banks on these deposits during the financial year are given below:

Bank A: Rs. 60,000/-
Bank B: Rs. 70,000/-
Bank C: Rs. 80,000/-
Bank D: Rs. 90,000/-

I am below 60 years. I do not have any other income. Therefore, my estimated income during the financial year will be less than Rs. 4 Lakhs and I am entitled to file Form 121. If I do not file Form 121, all the banks will deduct 10% income tax at source from my payments since all the interest amounts are more than Rs. 50,000/-. I will, therefore, have to submit four 121 forms, one to each bank. How to fill them?

As per the requirements of Form 121, I have to furnish following data in each of these forms:

Column 10. Estimated income for which this declaration is being made
Column 11(a). Total number of Form No. 121 filed earlier
Column 11(b). Aggregate amount of income for which Form No. 121 were filed earlier
Column 12. Aggregate amount of income for which declaration is made during the tax year [sum of column 10 and 11(b)]

It is easy to fill column 10. The expected interest amount can be specified in this column. It will be Rs. 60,000/- for Bank A, Rs. 70,000/- for Bank B, and so on. However, how to fill other columns in the forms. The information to be supplied in a form is relative to other forms. What I write in Form 121 for Bank B is relative to the information I gave in Form 121 for Bank A. And the information I give in the Form 121 for Bank C is relative to what I wrote in these forms submitted to Banks A and B, and so on.

Let us assume that I am filling all the four forms at the same time which will normally be the case for most of us. I do not know how other people do it, but I do it in the following way:

I plan that I will submit the forms to the banks in the following order:

1. Bank A
2. Bank B
3. Bank C
4. Bank D

Then I will give following information to Bank A:

Column 11(a). Total number of Form No. 121 filed earlier - Nil
Column 11(b). Aggregate amount of income for which Form No. 121 were filed earlier - Nil
Column 12. Aggregate amount of income for which declaration is made during the tax year [sum of column 10 and 11(b)] - Rs. 60,000/-

Details for Bank B:

Column 11(a). Total number of Form No. 121 filed earlier - 1
Column 11(b). Aggregate amount of income for which Form No. 121 were filed earlier - Rs. 60,000/-
Column 12. Aggregate amount of income for which declaration is made during the tax year [sum of column 10 and 11(b)] - Rs. 1,30,000/-

Details for Bank C:

Column 11(a). Total number of Form No. 121 filed earlier - 2
Column 11(b). Aggregate amount of income for which Form No. 121 were filed earlier - Rs. 1,30,000/-
Column 12. Aggregate amount of income for which declaration is made during the tax year [sum of column 10 and 11(b)] - Rs. 2,10,000/-

Details for Bank D:

Column 11(a). Total number of Form No. 121 filed earlier - 3
Column 11(b). Aggregate amount of income for which Form No. 121 were filed earlier - Rs. 2,10,000/-
Column 12. Aggregate amount of income for which declaration is made during the tax year [sum of column 10 and 11(b)] - Rs. 3,00,000/-

Appears simple? No, it is not. First of all, writing different information in different forms at the same time is prone to errors. Any time there may be some mix-up of the data in various forms and I will be giving incorrect data to the IT Deptt.

Secondly, I may not be able to submit the forms to various banks in the same order in which I had initially planned. Some banks accept a scanned copy of the form by e-mail which is faster, some banks are near my residence and I can personally visit them and submit a hard copy which takes a little more time, and to some banks, which are distant, I need to send the forms by post which is time-consuming. However, if the order of submission of the forms to various banks gets changed due to these issues, then a lot of the data which I specified in the forms may become wrong and I am liable to be punished for that.

One way to avoid this trouble is that I specify in Column 11(a) that I have previously submitted 3 forms (though it is not correct) in all the 4 forms. But in Column 11(b), the income amount will still be different. It will be Rs. 2,40,000/- for Bank A, Rs. 2,30,000/- for Bank B, Rs. 2,20,000/- for Bank C, and Rs. 2,10,000/- for Bank D. The chances of mistakes, thus, are not reduced much.

This is one problem which I always encounter while filing these forms. Given below is another problem which I have faced several times.

What if I open another FD in Bank A which will give me an interest of Rs. 10,000/- during the financial year after I submitted Form 121 to the bank? My estimated income for the year will still be below Rs. 4 Lakh and the bank should not impose TDS on my interest payments. However, as per rules, I should resubmit Form 121 to the bank with modified data otherwise the bank will start deducting IT on source not only on my future payments but also on interest already paid to me. What should I write in the revised form – How many forms have I submitted earlier? 3 or 4? There is no clarity from the IT Deptt. on this.

Due to these difficulties, it would have been better If they had deleted Column 11 altogether. And then there would have been no need to introduce Column 12 which was not there in Forms 15G/H. In any case, they are asking the tax-payer to furnish the estimated total income for the year in Column 13. That should be sufficient.

HUF NOT SPECIFIED –

Still another lapse – In Note 3, they have forgotten to specify that Form 121 can be furnished by an HUF also.

COUNTRY CODE –

In this new form they are asking you to write country code also while mentioning your phone no. Strange! Don’t they know India’s code is +91? If somebody is living abroad and still filing Form 121 (a rare case), it will be known from his address and they can easily find his country code on their own. Even more strange is that in Part B they want the bank/institution, to whom the form is submitted, also to write their country code. If the income is being generated/taxed in India, then obviously some organization, even if foreign, but having its office in India only, would be paying it. What will be their country code, then? Really amazing.

CHOICE BETWEEN OTR/NTR –

When they are asking so much data about other things, they should also have asked which Tax Regime will the declarant opt for while filing his ITR, since tax-free income limits are different under different regimes. Under OTR, tax-free incomes are Rs. 2.5 Lakh for a general citizen, Rs. 3 Lakh for a senior citizen and Rs. 5 Lakh for a super-senior citizen. Under NTR, tax-free income is same for everybody, i.e., Rs. 4 Lakh.

For last 2-3 years, ICICI bank has been asking me to furnish this declaration along with Form 15H. They do not accept forms 15G/H without this declaration.