From 1st April 2026, TDS compliance under IT Rules 2026 is no longer just about filing returns. With renumbered forms like Form 138, Form 140, and Form 144, businesses and CA firms must adopt a structured compliance system.
Most businesses deduct TDS.
Very few manage it properly.
That gap leads to:
- Section 200A notices
- Interest under 201(1A)
- Default mismatches
- Vendor disputes
- Compliance chaos
This guide gives you:
- ✅ Complete TDS Compliance Checklist 2026
- ✅ Internal TDS SOP for CA Firms
- ✅ Ready-to-implement TDS Delegation Matrix
- ✅ Risk management framework
- ✅ Downloadable PDF checklist
Why TDS Compliance Is Critical from 1 April 2026
Under IT Rules 2026, TDS form numbering has changed. For example:
- Salary TDS Return → Form 138
- Non-salary (Resident) → Form 140
- Non-resident → Form 144
- TCS Return → Form 143
If your internal system is not updated, incorrect filings will multiply correction workload.
TDS is not clerical work.
It is a risk control mechanism.
Complete TDS Compliance Checklist 2026 (Step-by-Step)
1. Before Making Any Payment
- Is TDS applicable under the relevant section?
- Resident or Non-Resident identified?
- PAN collected and verified?
- Lower / Nil certificate obtained (Form 128)?
- Declaration for non-deduction received (Form 121)?
- Specified senior citizen declaration (Form 125)?
- Non-resident payment? → Form 145 & Form 146 required?
2. TAN & Setup Compliance
- TAN obtained?
- Govt Entity → Form 134
- Others → Form 135
- Section properly mapped in accounting software
- Vendor master properly classified
3. Monthly Deduction & Deposit Control
- TDS deducted at time of credit/payment
- Deposited by 7th of next month
- March liability deposited by 30th April
- Interest under section 201(1A) checked if delay
4. Quarterly TDS / TCS Return Filing (IT Rules 2026)
| Nature | Form No. |
| Salary TDS | Form 138 |
| Non-salary Resident | Form 140 |
| Non-resident | Form 144 |
| TCS | Form 143 |
| VDA | Form 142 |
| Challan-cum-statement | Form 141 |
Wrong return filing increases correction cycles and compliance risk.
5. TDS / TCS Certificate Issuance
- Salary Certificate → Form 130
- Non-salary Certificate → Form 131
- Property TDS Certificate → Form 132 series
- TCS Certificate → Form 133
6. Lower/Nil & Special Declarations
- Lower/Nil Certificate → Form 128
- Non-resident proportion → Form 129
- Non-collection of TCS → Form 127
- No TDS Declaration → Form 126
7. Non-Resident & Remittance Compliance
- Information filing → Form 145
- CA Certificate → Form 146
- Statement by AD → Form 147
- IFSC Unit statement → Form 148
Non-resident TDS is a high-risk compliance zone.
8. Default Handling / Correction / Refund
- Refund claim → Form 139
- TDS default certificate → Form 149
- TCS default certificate → Form 150
- TDS credit application → Form 102
Ignoring TRACES defaults allows interest to accumulate silently.
TDS Return Forms Under IT Rules 2026 Explained
IT Rules 2026 introduced form renumbering that businesses must adapt to immediately.
- Form 138 – Quarterly Salary TDS Return
- Form 140 – Quarterly TDS Return (Resident Non-Salary)
- Form 144 – TDS Return for Non-Residents
- Form 143 – TCS Quarterly Return
- Form 142 – VDA TDS
- Form 141 – Challan-cum-statement
Failing to update internal templates to new form numbers creates confusion during audits.
Internal SOP for CA Firms – How to Build a TDS Control System
A structured TDS SOP for CA firms ensures consistency and reduces dependency risk.
Step 1: Client Risk Classification
Classify each client as:
- Low Risk – Salary + Few Vendors
- Medium Risk – Multiple Contractors
- High Risk – Foreign Remittance / TCS / Property
High-risk clients require senior review before filing.
Step 2: Monthly Workflow Structure
Define fixed timelines:
1st–3rd → Data collection
3rd–5th → Computation
Before 7th → Deposit
Quarter-end → Return filing
Within 7 days → Certificate issuance
Document everything in a central tracker.
Step 3: Non-Resident Compliance Desk
All cases involving Form 145 and Form 146 must undergo senior-level review.
Junior staff should not independently close foreign remittance cases.
Step 4: Notice & Default Handling SOP
Internal SLA: 3 working days for notice draft.
Track:
- 200A notices
- PAN mismatches
- Challan mismatches
- Late interest cases
Step 5: Document Storage Structure
Maintain structured folders:
Client Name
→ FY 2026-27
→ Monthly Challans
→ Quarterly Returns
→ Certificates
→ Notices
→ Non-Resident Cases
No scattered compliance records.
TDS Delegation Matrix – RACI Model Explained
A TDS Delegation Matrix eliminates ambiguity.
R – Responsible
A – Accountable
C – Consulted
I – Informed
Sample Delegation Matrix
Monthly TDS Deposit
| Activity | Execution | Senior | Partner | Client |
| Data Collection | R | A | ||
| Computation | R | C | A | I |
| Non-resident Review | R | A | I | |
| Challan Preparation | R | C | A |
Quarterly Return Filing
| Activity | Execution | Senior | Partner |
| Return Preparation | R | C | |
| Justification Review | R | A | |
| Final Approval | A |
If one staff member leaves and the system collapses, your firm is process-weak.
How to Implement This TDS Compliance System
- Create a shared compliance tracker.
- Assign one owner per client.
- Automate due-date reminders.
- Conduct quarterly review meetings.
- Maintain structured cloud documentation.
- Track default frequency per client.
TDS compliance must be system-driven, not memory-driven.
Frequently Asked Questions (FAQ)
What is the TDS Compliance Checklist 2026?
It is a structured control framework covering deduction, deposit, return filing, certificate issuance, and correction under IT Rules 2026.
Which forms apply under IT Rules 2026?
Key forms include Form 138, 140, 144, 143, 142, 141, 130, 131, 145, and 146.
What is Form 138 under IT Rules 2026?
Form 138 is the quarterly TDS return for salary payments.
How should CA firms structure a TDS SOP?
By defining timelines, risk classification, delegation matrix, and notice handling protocol.
What is a TDS Delegation Matrix?
It is a structured responsibility framework using RACI to assign accountability in TDS processes.
Download TDS Compliance Checklist & SOP PDF
If you want:
- Printable TDS Compliance Checklist 2026
- Editable TDS SOP Template
- TDS Delegation Matrix Sheet
- Risk Classification Framework
👉 Download the complete PDF here:
About the Author
CA Devesh Thakur
Partner in Nation Building
