Compliance Crisis: Form 156 Utility Gap

Compliance Crisis: The Missing Form 156 Utility for International Travelers

Status Report: April 24, 2026

A significant compliance gap has emerged following the implementation of the Income-tax Rules, 2026. While the new rules mandate that Indian residents with a PAN file Form 156 electronically before traveling abroad, the actual online utility remains unavailable on the official e-filing portal.

The Core Problem: Policy vs. Implementation

Effective April 1, 2026, Rule 228 introduced Form 156 as a mandatory "event-based" filing requirement for persons domiciled in India departing the country.

  • Mandatory Requirement: Every time a PAN-holding resident leaves India, they must submit an electronic declaration detailing their purpose of visit and estimated duration.
  • The Utility Gap: Despite the rule being "live," the designated link is currently not activated on the Income Tax e-filing portal.
  • Immigration Concerns: Growing apprehension regarding potential delays at airport immigration for non-compliance with a technically impossible process.

Understanding Form 156 vs. 157

The Income-tax Act, 2025 framework has streamlined travel reporting into two distinct categories:

Feature Form 156 (New) Form 157 (New)
Applicability Persons with a PAN and taxable income. Persons without a PAN or taxable income.
Filing Mode Electronic only via e-filing portal. Manual certificate/undertaking.
Frequency Event-based; every departure. Event-based; every departure.
Verification Electronic (EVC/DSC). Manual submission at ports.

Stakeholder Demands for Clarification

Tax professionals have issued urgent requests to the Central Board of Direct Taxes (CBDT) to address this roadblock:

  • Immediate Utility Rollout: Expediting the release of the electronic filing interface.
  • Grace Period: Issuing a circular for an interim waiver until digital infrastructure is operational.
  • Inter-Departmental Coordination: Ensuring the Ministry of Home Affairs prevents traveler harassment.

What Should Travelers Do Now?

  • Monitor the Portal: Regularly check the "Forms" section of the Income Tax website.
  • Maintain Records: Keep digital copies of your PAN and passport ready for when the utility goes live.
  • Stay Informed: Follow official CBDT social media handles for the "Utility Live" announcement.