Form 165 under the Income Tax Act: Applicability and Filing Guide

Overview

Form 165 under the Income Tax Act is a statement used for reporting Specified Financial Transactions (SFTs) to the Income Tax Department. It has been introduced under the Income Tax Act, 2025 as the renumbered version of the earlier Form 61A. Although the form number has changed, its primary objective remains the same: to help the Income Tax Department monitor specified high-value financial transactions and strengthen tax compliance.

In this article, we explain what Form 165 under the Income Tax Act is, its applicability, reportable transactions, filing process, due date, penalties, and how it differs from Form 61A.

What is Form 165 under the Income Tax Act?

Form 165 under the Income Tax Act is the new form prescribed for reporting Specified Financial Transactions (SFTs) under the Income Tax Act, 2025. It is the corresponding renumbered Form 61A after the renumbering of income tax forms. Form No. 165 is prescribed under Section 508(1) of the Income Tax Act, 2025, which requires specified persons to furnish a statement of specified financial transactions in the prescribed form and manner.

The purpose of Form 165 remains the same. It enables the Income Tax Department to receive details of specified high-value financial transactions from notified reporting entities, helping improve transparency and tax compliance.

In simple words, if your organization is required to report specified financial transactions, you will now file Form 165 instead of Form 61A under the new Income Tax Act.

To understand the form number changes in detail, read our guide on Major Renumbering of Income Tax Forms Explained.

Form 165 vs Form 61A: Key Differences

For a complete comparison, refer to our blog on Income Tax Act 2025 vs old income tax law.

Transactions Reportable in Form 165 under the Income Tax Act

The specific transactions to be reported in Form 165 are governed by Section 508(1) of the Income Tax Act, 2025 and the prescribed rules. Some reportable transactions and applicable thresholds include:

• Cash deposits of ₹10 lakh or more in one or more accounts, other than current accounts and time deposits, are reportable. Cash deposits or withdrawals of ₹50 lakh or more in one or more current accounts are also reportable by prescribed banking or post office entities.
• Cash payments exceeding ₹10 lakh in a financial year for demand drafts, pay orders, or prepaid instruments issued by the RBI.
• Share application money or receipts exceeding ₹10 lakh in a financial year from any person for acquiring shares issued by a company.
• Receipts exceeding ₹10 lakh in a financial year from any person for acquiring bonds or debentures issued by a company or institution.
• Share buy-backs exceeding ₹10 lakh in a financial year by listed companies.
• Credit card bill payments exceeding ₹10 lakh through non-cash modes, or exceeding ₹1 lakh in cash, in a financial year.
• Receipts from the sale of foreign currency, or expenses incurred in foreign currency, exceeding ₹10 lakh through credit cards, debit cards, traveller’s cheques, drafts, or other financial instruments.
• Receipts exceeding ₹10 lakh in a financial year from any person for acquiring units of a mutual fund.
• Sale or purchase of immovable property exceeding ₹30 lakh, reported by the Inspector General or Sub-Registrar appointed under the Registration Act, 1908.
• Cash receipts exceeding ₹2 lakh for the sale of goods or services by persons liable for audit under the corresponding provisions of the Income tax Act, 2025.

Information Required for Form 165 under the Income Tax Act

Before filing Form 165, the reporting entity should keep the following information ready:

• Name and details of the reporting entity
• PAN or TAN of the reporting entity
• PAN of the person involved in the transaction, wherever applicable
• Details of the specified financial transaction
• Date and value of each reportable transaction
• Customer or account holder details
• Any other information prescribed under the Income tax Rules

Ensuring complete and accurate information helps avoid validation errors and reduces the chances of receiving notices from the Income Tax Department.

How to File Form 165 Online?

Form 165 can be filed in the following simple steps. The basic filing process is as follows:

• Visit the Income Tax Department’s INSIGHT Reporting Portal.
• First-time reporting entities must register on the Reporting Portal and generate an Income-tax Department Reporting Entity Identification Number, wherever applicable.
• Existing reporting entities can log in using their registered credentials.
• Prepare the Form 165 statement in the prescribed format with the required reporting entity details and transaction information.
• Generate and validate the XML file using the applicable reporting utility.
• Sign and encrypt the prepared file with the required digital signature or validation file, as applicable.
• Upload the prepared statement package on the Reporting Portal / INSIGHT Portal.
• After successful validation, an upload confirmation message will appear on the screen confirming the upload status of Form 165.

Due Date for Filing Form 165

Form 165 is generally required to be filed on or before 31 May immediately following the financial year in which the transaction is recorded, unless another due date is prescribed. Certain SFT reporting categories, such as listed securities and mutuaal fund units may follow half-yearly filing requirements.

Reporting entities should complete the filing within the prescribed time to avoid penalties and ensure timely compliance. However, certain SFT reporting categories, such as listed securities and mutual fund units, may have different periodic filing requirements as prescribed.

Penalty for Non-Filing or Incorrect Filing of Form 165

Failure to furnish Form 165 within the prescribed time may attract a penalty of ₹500 per day under Section 454 of the Income-tax Act, 2025. If the default continues after notice, a higher penalty may apply as prescribed.

Some common situations that may result in penalties include:

• Failure to furnish the statement within the prescribed due date or after receiving notice.
• Furnishing inaccurate or incomplete information.
• Failure to rectify defects or incorrect information after receiving a notice from the Income Tax Department.
• Non-compliance with the reporting requirements prescribed under the Act and the Income-tax Rules.

Reporting entities should maintain proper records and ensure timely and accurate filing to avoid unnecessary penalties and compliance issues.

Get Professional Assistance from Ebizfiling

Filing Form 165 under the Income Tax Act requires accurate reporting of specified financial transactions and timely submission to the Income Tax Department. Any errors, omissions, or delays may result in notices or penalties. Ebizfiling simplifies the entire filing process by offering end-to-end compliance support.

Our experts help you:

• Determine whether your organization is required to file Form 165.
• Verify reportable transactions and applicable reporting thresholds.
• Assist with online filing on the Income Tax Reporting Portal.
• Ensure timely filing and compliance with the Income Tax Act, 2025.
• Provide professional support for notices, corrections, or filing-related queries.

For expert assistance, explore our business income tax return filing service.

Conclusion

Form 165 under the Income Tax Act is the prescribed form for reporting Specified Financial Transactions (SFTs) under the Income Tax Act, 2025. It corresponds the earlier Form 61A while continuing the same objective of reporting specified high-value financial transactions to the Income Tax Department. Reporting entities must understand the applicability, reportable transactions, filing process, due date, and penalty provisions to ensure compliance with the law. If your organization is required to file Form 165, timely and accurate reporting is essential to avoid penalties and maintain regulatory compliance.

Frequently Asked Questions