CA Forums

Forms 15G and 15H were self-declaration forms submitted to banks and financial institutions to prevent Tax Deducted at Source (TDS) on incomes such as interest, dividends, and other taxable payouts. Effective April 1, 2026, both the 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 asks you to furnish nearly the same data which Forms 15G/H used to. Only the placement of the items has been changed. Of course, there is one important change. Now you also have to provide information about the last two income tax returns filed by you, i.e., their acknowledgement numbers and your income assessed by the IT Deptt. in those returns. This data was not being asked in Forms 15G/H.

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 term - ‘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 a great innovation and are patting their own back for having great mercy on the tax payers and doing away with both ‘Assessment Year’ and ‘Previous Year’. Now they have coined a still new term - ‘Tax Year’. Can I ask them why they cannot use simple and beautiful ‘Financial Year’ and what was the need of this new term? 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?

COMBINING 15G/H INTO ONE FORM

The Income Tax Deptt. is proudly announcing that 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 invention! Could Albert Einstein ever do such a remarkable 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 income tax 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 prescribing two forms when only one was needed, has better sense now prevailed on the IT Deptt.? Well, yes and no. True, that now they have reduced one form, but in this Form 121 also you have to declare whether you are above 60 in Column 5(a) of Part A. Also, 1 out of 5 clauses under ‘Declaration’ in Part A 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.

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 any 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.

THE REAL STORY BEHIND THESE CLAUSES

OK, let me solve this mystery. Actually, the IT Deptt. makes a serious discrimination between taxpayers above 60 years (senior citizens) and those below this age (general citizens) regarding eligibility for filing Form 121. Senior citizens can file Form 121 as long as their income does not exceed Rs. 12 Lakh but others can file this form only if their income doesn’t cross just Rs. 4 Lakh.

This is why they previously used to have two forms: 15G (for general citizens) and 15H (for senior citizens). However, they never disclosed the above reason behind it. They always kept it as a closely guarded secret. And the Indian taxpayers never questioned them. They simply selected the designated form as per their age for filing.

This strange rule creates an anomalous and faulty situation. If a taxpayer under 60 years has a taxable income between 4 Lakh and 12 Lakh, he cannot file Form 121 and banks will impose TDS on all his interest payments. However, the entire TDS will be refunded when he files his Income Tax Return!

The IT Deptt. has issued detailed 6-page Frequently Asked Questions (FAQs) on Form 121. In these FAQs, they have described the objectives of Form 121 as:

1. To avoid unnecessary TDS where no tax is payable

2. To reduce the burden of claiming refunds

So, this is the way they are achieving their objectives!

Anyway, let us return to the clauses we were discussing. Can anybody with an average or even above-average IQ find out that clauses (iii) and (iv) really describe this discriminatory rule? Can one even remotely guess this? I have observed that almost nobody, not even financial advisors and investment brokers, know this.

This provision is so important that they should clearly specify it at the top of Form 121, just under its title. They should clearly write: “This form can be filed by taxpayers aged 60 years or above if their estimated income does not exceed Rs. 12 Lakh, and by taxpayers below 60 if their estimated income does not exceed Rs. 4 Lakh.”

Gimmicks like clauses (iii) and (iv) simply do not work. If you knowingly make a stipulation that lacks sound logic, you should also be brave enough to state it clearly. Trying to hide it under fancy words is a flawed strategy.

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 section/department for processing of each form. Without these identifiers in Form 121, banks will face considerable difficulty in directing the forms to the correct department for doing the needful.

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 bonds without it. Therefore, she sent it on WhatsApp to the bank.

DUPLICATION OF DATA

The person filling Part B of Form 121 has been asked to duplicate a lot of items which the declarant has furnished in Part A. These are:

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 meticulously 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 FORMS 121 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 in Column No. 11. 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 is less than Rs. 4 Lakh 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 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 dependent on the information supplied in other forms. What I write in Form 121 for Bank B is dependent on the information I gave in Form 121 to Bank A. And the information I give in the Form 121 to Bank C is dependent on 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 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 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 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 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/brokers 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 three forms (though it is not correct) in all the four 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 can 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.

What will happen if after submitting all the forms, I learn that the form which I sent to Bank A by post has been lost in transit and I need to submit it again? Can I take another printout/photocopy of the same form which I had submitted to the bank and send it? No, not at all. I will have to fill the form again with totally new data. Further, all the data which I filled in the forms for Banks B, C and D would have already become incorrect.

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 Form 121 they are asking you to write country code also while mentioning your phone no. Strange! Don’t they know what India’s country code is? If an Indian is living abroad and still filing Form 121 (a rare, perhaps impossible 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) 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 could 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.

THE LAST WORD

I learnt from reliable sources that the Nobel Committee is seriously considering the IT Deptt. for next year’s prize in ‘Economic Sciences’ category for their groundbreaking achievement of replacing Forms 15G/H with Form 121.

I have submitted a proposal to the Income Tax Deptt. If they implement my proposal, there will be no need to file Form 121. See the post given below:

PAPERLESS SYSTEM TO REPLACE FORM 121