A S BANKA ADVISORS

Most tax changes announce themselves as a new rate or a new threshold. This one is quieter, and for your finance function it is more disruptive. From the quarter ended 30 June 2026, the first quarter governed by the Income-tax Act 2025 and the Income-tax Rules 2026, the TDS and TCS returns your team has filed for a decade have been renumbered. Form 24Q is now Form 138, and your first-quarter return is due 31 July 2026. Nothing about how you compute tax has changed. Everything about the paperwork has, including the section reference printed inside the return.

The old-to-new mapping your team should pin to the wall

The obligation to file the statement now sits in Section 397 of the Income-tax Act 2025, not in the old Section 200(3) or 206C(3). Two genuinely new forms sit alongside the renumbered set: Form 141, a challan-cum-statement, and Form 142 for virtual digital asset transfers.

The July calendar, and the one date that trips people up

Deposit your June 2026 TDS and TCS by 7 July. File every Q1 return, Form 138, 140, 144 and 143, on or before 31 July 2026. The trap is the TCS return. As Form 27EQ it was due on 15 July. As Form 143 it is now aligned to the TDS timeline and due on 31 July. That helps the collector who diarised 15 July out of habit, but it catches out anyone who assumes the TCS return is already overdue on the 16th. File both TDS and TCS on or before 31 July.

Treat this as an operations problem, not a year-end one

Every entity with a TAN is in scope: every company, LLP, firm, trust and proprietor that deducts tax on salaries, contractor payments, professional fees, rent, interest or commission, or that collects tax at source. There is no size threshold and no opt-out. If your accounting software vendor has pushed the FY 2026-27 update, you are largely insulated. The exposure sits with manual filers, small deductors on the department utility, and anyone reconciling against an internal register that still references the old form names. Upload an old Form 24Q or 26Q for the June 2026 quarter and it will be rejected on validation at TRACES, while the late-fee clock keeps running. Brief your payroll team too: the salary certificate employees expect as Form 16 will now be issued as Form 130, and the investment declaration you collect is now Form 124.

The cost of getting it wrong

The late-filing fee that most deductors know as Section 234E continues under the Act 2025: Rs 200 for every day of delay, capped at the total tax in the return. It stacks on top of, not instead of, interest and any separate penalty for non-filing or incorrect particulars. The more expensive exposure is interest on late deposit: 1.5 percent per month or part of a month, running from the date tax was actually deducted, not from the 7th of the following month. A single day late on the 7 July deposit therefore attracts a full month of interest.

What to do before 31 July

1. Confirm your TDS and payroll software vendor has pushed the FY 2026-27 form update.
2. Update SOPs, templates and filing registers to the new numbers: 138, 140, 144, 143, 130, 131, 124.
3. Deposit June 2026 TDS and TCS by 7 July, because interest runs from the deduction date.
4. File all Q1 returns, Form 138, 140, 144 and 143, on or before 31 July 2026.
5. Do not mix old and new numbers. The old forms apply only to transactions up to 31 March 2026.

Download the full carousel PDF for a visual, wall-chart version of the mapping, the July calendar and the penalty math.

Not sure your filings are on the new forms, or want a second pair of eyes on your Q1 statements before the 31 July deadline? Book a quick call: https://calendly.com/asbanka-info/30min. CA Adityavikram Banka, Founder, A S Banka Advisors Private Limited.