April 2026 marks a genuine break from the past. The Income Tax Act, 1961, no longer exists as operative law. In its place, the Income Tax Act, 2025 came into force on 1 April 2026, bringing with it the Income Tax Rules, 2026 and an entirely new set of statutory forms.
For most taxpayers, the headline change is simple: Form 16 is now Form 130. Form 26AS is now Form 168. Form 15G and 15H have been merged and replaced by Form 121. But for employers, deductors, and compliance teams in Delhi, Mumbai, and Bengaluru, the implications go further than updated labels. Wrong form numbers in TDS returns for Tax Year 2026-27 will be rejected at the CPC. The portal will not accept old references for the new tax year. This is not a grace period situation.
What Is the New Tax Form Renumbering 2026?
The Income tax form renumbering 2026 did not happen through a circular or a notification tucked into a finance bill. It is the result of Parliament passing the Income Tax Act, 2025, on 12 August 2025. Presidential assent followed on 21 August 2025. The Income Tax Rules, 2026 were notified by CBDT on 20 March 2026.
One thing to be clear about before the table below. New forms apply to Tax Year 2026-27 onwards, meaning income earned from 1 April 2026. Anything related to FY 2025-26 and earlier stays under the old Act and old forms. The e-filing portal runs both systems simultaneously during this transition.
Old vs New Income Tax Forms
With the implementation of the Income Tax Act, 2025, several tax-related forms have been renumbered and consolidated. Below is a simplified breakdown of how the old forms correspond to the new ones:
1. Salary TDS Certificate
- Earlier known as Form 16, this document has now been replaced by Form 130.
2. Non-Salary TDS Certificate
- Previously issued as Form 16A, it is now renamed as Form 131.
3. Tax Credit Statement
- The widely used Form 26AS has been replaced with Form 168.
4. Non-Deduction Declaration
- Forms 15G and 15H have been merged into a single form, now called Form 121.
5. Investment Declaration
- The earlier Form 12BB is now known as Form 124.
6. Tax Audit Report
- Forms 3CA, 3CB, and 3CD have been consolidated into a single Form 26.
7. Salary TDS Quarterly Return
- The quarterly return earlier filed as Form 24Q is now Form 138.
8. Non-Salary TDS Quarterly Return
- Previously filed as Form 26Q, it is now replaced by Form 140.
9. No-PAN Declaration
- The old Form 60 has been updated to Form 97.
10. Lower Deduction Certificate
- Earlier known as Form 13, it is now Form 128.
What Employers and Deductors Must Update Immediately
15 June 2026 is the deadline for issuing Form 130 to salaried employees. This is the statutory deadline for the TDS certificate, which was Form 16, now Form 130, for Tax Year 2026-27. It comes from the TRACES portal, the same way Form 16 always did. What has changed is the form reference in the system. If your payroll vendor has not pushed this update, follow up now.
For vendor and contractor payments, the change is already overdue. Form 15G and Form 15H are invalid for Tax Year 2026-27. Any vendor submitting either of those forms for the current year is giving you a document that has no standing under the new Act. The correct form is Form 121. Accepting the wrong declaration shifts TDS liability to the deductor.
For lower deduction certificates, Section 197 of the old Act is gone. Fresh applications from 1 April 2026 must go through Form 128 under Section 395(1) of the Income Tax Act, 2025, filed electronically on TRACES. Certificates already issued under the old Section 197 remain valid for Tax Year 2026-27 if they covered projected receivables for that year.
Step-by-Step Guide to Accessing New Forms on the Portal
- Log in at incometax.gov.in using your PAN credentials.
- Go to e-File, then Income Tax Forms, then File Income Tax Forms. For Tax Year 2026-27 filings, select the section labelled "Forms under Income Tax Act, 2025."
- Use the searchable Form Navigator tool on the portal for specific edge-case mappings.
- For Form 168, the replacement for Form 26AS, go to the Annual Information section after login. During the transition year, both statements sit separately on the portal: the old AIS for pre-April 2026 periods, and Form 168 for Tax Year 2026-27 onwards.
- For Form 130, employers access it through TRACES using TAN credentials.
- Navigate to Downloads and generate the certificate only after the relevant quarterly TDS return has been filed and processed. You cannot generate Form 130 for a quarter whose TDS return is still pending.
Impact on Payroll and TDS Filing in Delhi, Mumbai, and Bengaluru
Bengaluru tech companies running payroll through SAP, Workday, or Oracle HCM need more than a software patch. Bulk TDS certificate generation, still mapped to Form 16 will fail at TRACES for Tax Year 2026-27. The configuration update needs to happen at the template level. Separately, the new rules extend the 50% HRA exemption to Bengaluru, Pune, Hyderabad, and Ahmedabad, so payroll recalculations for employees in those cities are part of the same update cycle.
Mumbai financial services firms issuing non-salary TDS certificates must shift from Form 16A to Form 131 on TRACES. High-volume payers like banks, NBFCs, and brokerages should also audit their vendor onboarding to ensure Form 121 is being collected, not the old declarations.
For Delhi corporates and PSUs handling multi-city payroll, the quarterly TDS return templates need immediate attention. Salary TDS returns are now Form 138, replacing Form 24Q. Non-salary TDS returns are now Form 140, replacing Form 26Q. Any return filed under old form numbers for Tax Year 2026-27 transactions generates a validation error at the CPC. A tax law firm Delhi or internal tax team should run this mapping exercise before the July 2026 first-quarter deadline.
CLC Checklist: ERP and Software Updates Required
Before June 2026, confirm the following with your payroll vendor and tax team.
- Payroll software must generate Form 130 for the TDS certificate and reference Form 138 and Form 140 for quarterly TDS returns. Investment declaration workflows need to reflect Form 124 instead of Form 12BB.
- On TRACES, Form 130 generation depends on the quarterly return being processed first. Verify API credentials are live and your vendor's schema reflects the new form references.
- Send written notice to all vendors, contractors, and banks. Form 121 is the only valid non-deduction declaration for Tax Year 2026-27. Fixed deposit holders and other investors submitting Form 15G or 15H for the current year should be sent back to submit Form 121.
- Update all employee-facing HR content like payroll FAQs, self-service portals, onboarding documents to explain the Form 130 and Form 168 changes before the June deadline. Waiting until employees start asking is too late.
Review vendor contracts and banking mandates that name old form numbers. Any document governing Tax Year 2026-27 obligations that still references Form 15G, Form 15H, or Form 16 needs updating. Maintain separate document folders for FY 2025-26 and Tax Year 2026-27 filings. Mixed references across periods slow down assessments and scrutiny responses considerably. Our guidance on building robust regulatory compliance frameworks covers the contractual alignment side of this in more detail.
Conclusion
July 2026 is when the first quarterly TDS return for Tax Year 2026-27 falls due. That is the real deadline. Everything in this checklist feeds into that date. CPC rejections, interest penalties, and notice triggers are all avoidable with timely ERP updates and vendor communication done now.
The teams at CLC handle form-transition audits, ERP vendor coordination, and compliance implementation under the new Act.
Contact Commercial Law Chamber for a compliance consultation today.
Frequently Asked Questions (FAQs)
1. What is Form 130 in the new tax regime?
Form 130 is what Form 16 has become under the Income Tax Rules, 2026. Employers issue it to salaried employees showing salary paid and TDS deducted for the tax year. It comes from the TRACES portal in digital format and must be issued by 15 June for Tax Year 2026-27.
2. Can my TDS return be rejected if I use old form numbers for Tax Year 2026-27?
Yes. Salary TDS returns filed as Form 24Q instead of Form 138, or non-salary returns filed as Form 26Q instead of Form 140, will generate validation errors. The portal does not accept old form references for current tax year transactions.
3. Where can I find the official mapping of all new tax forms?
The full mapping is on incometax.gov.in. The Form Navigator tool under CBDT Notification No. 22/2026 has a searchable index. New ITR forms FY 2026-27 are under e-File, then "Forms under Income Tax Act, 2025."
4. Do I need to re-submit Form 15G if I already submitted it before March 2026?
Submissions for FY 2025-26 stay valid for that period. For Tax Year 2026-27, the correct form is Form 121. It replaces both Form 15G and Form 15H. The department now issues one UIN per PAN per tax year instead of separate UINs for each payer relationship.