A Form 15CA/15CB compliance audit identifies every foreign remittance made during the year, determines which of those remittances required a 15CA declaration and a 15CB accountant's certificate (excluding remittances that fall within the specified exempt list), confirms the certified amount and the withholding tax rate stated in the 15CB match the amount actually remitted and the rate actually applied by the bank, and checks that the form was filed before the remittance was made rather than regularised afterward.
Identifying which remittances were in scope
- Obtain the full list of foreign outward remittances from the bank's FIRC/remittance advices for the year, not only the ones the entity has already classified as requiring 15CA/15CB — the completeness check needs an independent starting population.
- Check each remittance against the specified list of payments exempted from the 15CA/15CB requirement, rather than assuming a remittance type is exempt because it was treated that way in a prior year.
- For remittances the entity classified as not chargeable to tax in India and therefore outside the certification requirement, obtain the basis for that conclusion — a self-declaration without supporting analysis is a gap worth raising.
Matching the certificate to the actual remittance
| Check | Evidence | What it catches |
|---|---|---|
| Certified amount vs actual remittance | 15CB certificate, bank remittance advice | A remittance made in instalments where only the first was certified, or a top-up sent without a fresh certificate |
| Withholding rate applied | 15CB computation, actual TDS deducted and deposited under section 195 | Rate certified under a DTAA benefit that was not actually supported by a valid Tax Residency Certificate from the payee |
| Timing | 15CA filing date, remittance date | Remittance made before the form was filed, which is a procedural lapse even if the tax position itself is correct |
| DTAA benefit support | Tax Residency Certificate, Form 10F | DTAA rate applied without the payee furnishing a valid TRC for the year of payment |
Regulatory requirement
The list of remittances exempt from 15CA/15CB, the certificate format, and the conditions for claiming a DTAA benefit including the Tax Residency Certificate requirement are prescribed under the Income Tax Rules. Confirm the current list and conditions before concluding on a specific remittance.
A DTAA rate lower than the domestic withholding rate is frequently applied without the payee's Tax Residency Certificate actually being on file for the relevant year — the certificate from a prior year, even for the same payee, is not sufficient. This is one of the more common findings when 15CB files are reviewed after the fact.
This is practical guidance written for audit teams, not an authoritative statement of any standard or statute. Standards, forms and timelines change. Check the current text issued by the ICAI and the relevant authority before relying on anything here in an audit file.
Related resources
- Audit workflow & automationSA 250: consideration of laws and regulations, and why direct vs. indirect mattersThe auditor is not a compliance officer. SA 250 draws a specific line around what they're actually responsible for noticing.
- CARO & Companies ActCARO clause 3(xvi): RBI registration, and when a company is conducting NBFC business without knowing itA company can be conducting NBFC-type business in substance — significant lending or investment activity — without ever formally describing itself that way, and still trip this clause.
- Payroll & employee costTDS on salary: audit testing approachRecomputing TDS for a sample against the declared regime, matching to Form 24Q, and reconciling TDS deducted to deposited and to the payroll register.
- Related parties & disclosuresIdentifying related parties: the audit starting pointA client declaration is a starting point for the related-party list, not evidence of it. How to build and cross-check the list independently.
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