πŸ“’ Income Tax Due Date – Form No. 121: 7 October 2026

Important Income Tax Compliance Update for Payers

The Income-tax Rules, 2026 have introduced several changes in the way tax deduction declarations are handled. One important change is the introduction of Form No. 121, which replaces the earlier Forms 15G and 15H for declarations relating to receipt of certain incomes without deduction of tax.

For the quarter ending September 2026, persons responsible for paying specified income and receiving Form No. 121 declarations must ensure that the required declarations are properly reported within the prescribed timeline.

πŸ“… Due Date: 7 October 2026

This deadline is particularly relevant for payers who received Form No. 121 declarations during the quarter ending September 2026. Proper reporting, identification and record-keeping are important parts of the new TDS compliance framework.

What Is Form No. 121?

Form No. 121 is a declaration under Section 393(6) of the Income-tax Act, 2025, read with Rule 211 of the Income-tax Rules, 2026.

It is designed for eligible taxpayers who declare that tax should not be deducted at source on specified income because their estimated tax liability satisfies the prescribed conditions.

Under the earlier Income-tax Rules, taxpayers used Form 15G and Form 15H for similar purposes. From Tax Year 2026-27, Form No. 121 is the prescribed declaration under the new framework. The Income Tax Department confirms that the eligibility principles continue under Section 393(6), although the form structure has been changed.

Form 121 and the Earlier Forms 15G & 15H

The transition to Form No. 121 is an important change for taxpayers, banks, financial institutions and other payers.

Earlier:

  • Form 15G was generally used by eligible resident individuals below 60 years and certain other eligible persons.
  • Form 15H was used by eligible resident senior citizens.

Under the 2026 framework, these declarations are consolidated into Form No. 121.

The form contains details relating to the declarant, PAN, residential status, age where applicable, nature of income, estimated income and estimated total income.

Therefore, businesses and institutions that previously handled Forms 15G and 15H should ensure that their internal TDS processes have been updated for Form No. 121.

What Is the 7 October 2026 Deadline?

The compliance calendar for October 2026 provides 7 October 2026 as the due date for uploading the recipient declarations received in Form No. 121 during the quarter ending September 2026.

This means the relevant payer should review declarations received during the quarter and complete the prescribed reporting within the deadline.

The deadline should not be confused with the date on which an individual submits Form No. 121 to the payer. The declaration is furnished by the eligible recipient to the payer, while the payer has separate responsibilities relating to identification and reporting.

Who Needs to Pay Attention?

The compliance is particularly relevant to organisations and persons who make payments covered by the provisions of Section 393(6) and receive Form No. 121 declarations.

Examples can include:

  • Banks and financial institutions
  • Certain companies making specified payments
  • Other eligible payers covered by the TDS provisions
  • Organisations receiving Form No. 121 declarations from payees
  • Payers responsible for maintaining TDS records and quarterly reporting

The exact applicability depends on the nature of the payment and the requirements under the Income-tax Act, 2025 and Income-tax Rules, 2026.

Therefore, businesses should not assume that every payer is required to file Form No. 121 information. Applicability should be reviewed based on the actual payments and declarations received.

What Is the Role of the Payer?

The new framework places significant responsibility on the payer.

Under Rule 211, the payer is required to facilitate the furnishing of the declaration and allot a Unique Identification Number (UIN) to each Form No. 121 declaration received during the relevant quarter.

The CBDT's Directorate of Income-tax (Systems) has prescribed a procedure for generation and allotment of the UIN and quarterly furnishing of the relevant information.

This means the payer should have a proper system for:

  1. Receiving Form No. 121.
  2. Verifying the declaration.
  3. Capturing the PAN and relevant details.
  4. Generating/allotting the prescribed UIN.
  5. Maintaining the declaration.
  6. Reporting the declaration in the required statement.
  7. Completing the compliance within the prescribed timeline.

Why Is the UIN Important?

The Unique Identification Number creates a systematic mechanism for tracking Form No. 121 declarations.

The prescribed procedure provides for a 26-character UIN containing information relating to the sequence number, tax year and TAN of the payer.

The UIN therefore helps connect:

Form No. 121 → Declarant → Payer → Tax Year → TAN → Quarterly Reporting

Businesses should avoid manually maintaining incomplete or inconsistent identification records because errors in the UIN or related information can create reconciliation issues later.

Reporting Is Required Even When No Tax Is Deducted

One of the important aspects of the new framework is that reporting does not disappear merely because no TDS was deducted.

Rule 211 requires the payer to furnish the prescribed statement containing particulars of declarations received during the quarter along with the UIN, even if no tax has been deducted during that quarter.

This is an important compliance point.

For example, if a payer receives several valid Form No. 121 declarations and consequently does not deduct tax from those specified payments, the payer should not assume that there is no reporting requirement.

Proper reporting remains necessary.

Documents and Records Should Be Maintained

Businesses should maintain a complete Form No. 121 compliance file.

The records may include:

  • Original Form No. 121 declarations
  • PAN details
  • UIN records
  • Details of income covered by the declaration
  • Payment/credit details
  • Relevant ledger accounts
  • TDS working papers
  • Quarterly reporting records
  • Supporting verification documents
  • Communication with the recipient
  • Evidence of electronic submission, where applicable

The Income-tax Rules also provide for the declaration to be made available to an income-tax authority for verification or proceedings within the prescribed retention period.

Therefore, record retention should form part of the organisation's TDS compliance policy.

Common Mistakes to Avoid

Businesses handling Form No. 121 should be careful about several common mistakes.

1. Missing the quarterly deadline

Waiting until the last day can create avoidable technical and documentation problems.

2. Treating Form 121 like the old process

The old Forms 15G and 15H have been replaced by the new Form No. 121 framework for the relevant tax year.

3. Incorrect PAN

PAN is an important part of the declaration and reporting process. Incorrect PAN information can lead to reconciliation problems.

4. Missing UIN

Each applicable declaration needs the prescribed identification mechanism.

5. Assuming nil TDS means nil reporting

The quarterly reporting requirement applies even where no tax was deducted in the quarter.

6. Poor document retention

Declarations and related records should be preserved systematically.

Practical Compliance Checklist for 7 October 2026

Before the deadline, businesses should consider the following checklist:

✅ Identify all Form No. 121 declarations received during the July–September 2026 quarter.

✅ Verify the PAN and basic details of each declarant.

✅ Check that the declaration relates to the relevant tax year.

✅ Review the nature and amount of income covered.

✅ Generate or allot the prescribed UIN.

✅ Reconcile declarations with payment and ledger records.

✅ Verify TDS treatment.

✅ Ensure quarterly reporting is complete.

✅ Check the data before uploading/submission.

✅ Preserve acknowledgements and supporting documents.

Why Businesses Should Take Form 121 Seriously

Form No. 121 may appear to be a simple declaration, but the compliance process involves both the recipient and the payer.

For the recipient, the declaration is intended to support non-deduction of tax where the prescribed conditions are satisfied.

For the payer, receiving the declaration creates reporting, identification and record-keeping responsibilities.

This makes internal controls particularly important for banks, financial institutions and other organisations processing large numbers of payments.

A centralised system can help organisations track declarations, UINs, payment details and quarterly reporting more efficiently.

Conclusion

Form No. 121 is an important change under the Income-tax Rules, 2026. It replaces the earlier Forms 15G and 15H for the relevant declarations and introduces a structured process for receiving, identifying and reporting such declarations.

For the quarter ending September 2026, the relevant compliance deadline is:

πŸ“… 7 October 2026

Businesses and other applicable payers should review all Form No. 121 declarations received during the quarter, ensure proper UIN allocation, reconcile the information with their payment records and complete the required reporting within the prescribed timeline.

Tax compliance is not only about paying tax—it also includes accurate reporting, documentation, reconciliation and timely submission of statutory information.

Stay updated with the latest Income-tax Rules, maintain proper records and avoid last-minute compliance pressure.

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