Forms 138, 140, 143 and 144: The New TDS Returns, the Dates, and the Two-Year Clock on Every Mistake

Four times a year, an accounts team in India lives by a date. In the last week of the month the challans come out, the PANs get one more look, and someone asks the question that has been asked every quarter for as long as anyone in the room remembers: is the 26Q done?

This quarter, there is no 26Q to do.

From tax year 2026-27, quarterly TDS and TCS statements are filed on new forms under the Income-tax Rules, 2026. The first quarter went in by 31 July. The second, for July to September, is due on 31 October 2026. What the team actually does has barely changed. What each form is called, where some fields sit, and how long a mistake can still be put right have all changed, and the last of those has a deadline of its own.

Four forms, four new names

Rule 219(1) of the Income-tax Rules, 2026 says which statement carries which deduction.

• Form 138 is for tax deducted from salary under section 392, and on the income of a specified senior citizen under section 393(1). It replaces Form 24Q.
• Form 140 is for tax deducted on other payments to residents (other than those not ordinarily resident): contractors, professionals, rent, interest, commission. It replaces Form 26Q.
• Form 144 is for tax deducted on payments to non-residents, and to residents who are not ordinarily resident. It replaces Form 27Q.
• Form 143 is for tax collected at source under section 394(1). It replaces Form 27EQ.

Two more forms sit beside these four. Form 141 is the challan-cum-statement for tax deducted on rent by a person who is not a specified person, on buying immovable property, on contract work, commission or professional fees paid by an individual or HUF, and on transfer of a virtual digital asset (Table serials 2(i), 3(i), 6(ii) and 8(vi)). It is due within thirty days from the end of the month of deduction, not quarterly, under rule 219(5). Form 139 is the deductor's own claim for a refund of TDS paid, under rule 219(6).

The calendar, and the one date that moved

Under rule 219(4), each quarter's statement is due at the end of the month after the quarter closes, and the last quarter's at the end of May: 31 July, 31 October, 31 January and 31 May.

For TDS, those are the dates teams already knew. For TCS, they are not. Form 27EQ was due on the 15th: 15 July, 15 October, 15 January, 15 May. Form 143 keeps the TDS calendar. Nobody is penalised for filing early, but a firm that kept two calendars, one for TDS and one for TCS, is now keeping one too many.

Paying the tax runs on its own clock, and that one did not move: by the 7th of the following month, and for March by 30 April, under rule 218(2).

Inside Form 140

The first page of Form 140 is familiar: the deductor, the TAN, the person responsible, the challans. The deductee sheet behind it is where old habits break.

• Section codes are four-digit numbers. Note 15 to the form lists them, 1004, 1005 and onward, against each serial of the section 393 Tables. The "94C" and "94J" that a team types from memory have nothing to point to, because sections 194C and 194J no longer exist: a contractor is now section 393(1), Table serial 6(i), and professional fees are serial 6(iii).
• Form 121 has its own column. Where nothing was deducted because the deductee gave a declaration under section 393(6), the one that used to be Form 15G or 15H, the statement asks for the Unique Identification Number of the Form 121 they submitted.
• Reasons are still letters. A lower deduction on a certificate under section 395(1) is A. No deduction on a Form 121 declaration is B. A higher rate because the deductee gave no PAN is C. A transporter is T, and a payment below the threshold is Y.
• The challan must match the portal exactly. Note 8 to Part B asks for the BSR code, date and challan serial "exactly the same as available at TIN 2.0/TRACES portal".
• The late fee has a column of its own, column (D) of Part B, for the fee under section 427.

What a late day costs

Two provisions apply, and they work differently.

The fee is automatic. Section 427 charges ₹200 for every day the statement is late, never more than the tax deductible or collectible, and it has to be paid before the statement is filed. Ten days late on a quarter with ₹8,000 of TDS costs ₹2,000. Sixty days late on the same quarter costs ₹8,000, not ₹12,000.

The penalty is at the officer's discretion, and it is larger. Under section 461, the Assessing Officer may impose a penalty of ₹10,000 to ₹1,00,000 for a statement filed late or with incorrect information. For lateness alone there is a shelter: no penalty if the tax, the fee and any interest were paid, and the statement went in within one month of the due date. That month is not new. The 1961 Act's shelter in section 271H(3) had already been cut from a year to a month from 1 April 2025. But a team that learned the rule before then still remembers a year.

For the statement due on 31 October 2026, the month ends on 30 November 2026.

Two years to fix a mistake

This change carries the most money, because a correction statement is how a deductee's missing credit gets fixed. Under section 397(3)(f), a correction statement can be delivered only within two years from the end of the tax year in which the statement was due. The section also applies this, in terms, to statements delivered under section 200 of the 1961 Act.

Work it through. A statement that fell due in financial year 2024-25, which means the fourth quarter of 2023-24 (due 31 May 2024) and the first three quarters of 2024-25, can be corrected until 31 March 2027. On the section's own words, statements that fell due in 2023-24 or earlier are already outside the window. The CBDT has not said whether the savings clause in section 536 keeps the 1961 Act's longer limit alive for them, so file those corrections now rather than rely on it. The statement you file this October can be corrected until 31 March 2029.

If a deductee has been chasing a missing credit from 2024, the date that matters is not their return. It is 31 March 2027.

Before 31 October

• File the July to September quarter on Form 138, 140, 143 or 144, not on the form from last year's folder.
• Give every row in the deductee sheet its four-digit code from Note 15. Look each one up; don't map them from memory.
• Carry the Form 121 Unique Identification Number for every declaration that meant nothing was deducted.
• Match every challan to TIN 2.0 or TRACES digit for digit before the file is generated.
• If the statement will be late, pay the section 427 fee first, and file by 30 November.
• List the statements that fell due in 2024-25 with open defaults or unmatched credits, and correct them before 31 March 2027.

Where this comes from

The forms, their fields and the due dates are from the Income-tax Rules, 2026 as published in the Gazette of India, G.S.R. 198(E), 20 March 2026: rules 218 and 219, and Forms 138 to 144 in Appendix III. The fee, the penalty and the correction window are from the Income-tax Act, 2025 as amended by the Finance Act, 2026: sections 397(3)(f), 427 and 461. None of this changes how much is deducted, or when it is deposited. It changes what the statement is called, how it is filled in, and how long it can still be put right.