Form 24Q is now Form 138: what employers must change under the Income-tax Act, 2025

The Income-tax Act, 2025 and the Income-tax Rules, 2026 came into force on 1 April 2026. For payroll teams, the substance of salary TDS has not changed much. What has changed is almost every number you are used to: the form numbers, the section references and the name of the year itself.

If your payroll software, templates or internal checklists still say "Form 24Q" or "Form 16", they are now out of date for anything relating to the period from 1 April 2026.

The new form numbers at a glance

What it is	Old form (Income-tax Act, 1961)	New form (Income-tax Act, 2025)
Quarterly TDS return, salary	Form 24Q	Form 138
Quarterly TDS return, resident non-salary	Form 26Q	Form 140
Quarterly TCS return	Form 27EQ	Form 143
Quarterly TDS return, non-residents	Form 27Q	Form 144
Salary TDS certificate to employees	Form 16	Form 130
Non-salary TDS certificate	Form 16A	Form 131
Employee declaration of deductions	Form 12BB	Form 124

Salary TDS itself is now governed by section 392 of the new Act, in place of the old section 192. The terms "previous year" and "assessment year" are replaced by a single "tax year", so April 2026 to March 2027 is Tax Year 2026-27.

Which form applies depends on the period, not the filing date

This is where most errors will happen during the transition year.

• Anything for January–March 2026 (Q4 of FY 2025-26) stays under the old Act and old forms, even if you file or correct it later in 2026. A correction to that quarter goes on Form 24Q.
• Anything from April 2026 onwards (Tax Year 2026-27) goes on the new forms. The first salary TDS return on Form 138 was the one for April–June 2026.

A single employer will therefore legitimately be filing both old and new forms in the same calendar year. Keep them clearly separated in your records.

Due dates are unchanged for TDS returns

The quarterly TDS return due dates follow the familiar pattern: 31 July, 31 October, 31 January and 31 May for the four quarters. One change to note if you also collect TCS: the first-quarter TCS return now shares the 31 July due date, rather than the earlier 15 July.

Salary TDS certificates for the 2025-26 year were issued on Form 16 by 15 June 2026. The first certificates on Form 130 will be for Tax Year 2026-27, issued in 2027.

A checklist for payroll and finance teams

1. Update your software. Confirm that your payroll and TDS return software has released the Form 138, 140, 143 and 144 formats and the new section codes.
2. Update employee-facing templates. Investment declaration requests should now reference Form 124, and year-end communication should reference Form 130.
3. Separate the two regimes in your records. Tag filings and corrections by period, so old-period corrections do not end up on new forms.
4. Reconcile challans before filing. Match each month's TDS deposit to the return before upload. Mismatches are the most common cause of defaults and notices.
5. Brief your team and your vendors. Anyone who prepares, reviews or files TDS on your behalf should be working from the same updated checklist.

How Procor can help

Procor's payroll compliance team handles TDS on salary, quarterly returns and employee certificates as part of a monthly statutory calendar, alongside EPF, ESIC, professional tax and labour welfare fund. If you would like a second pair of eyes on your transition to the new forms, book a free consultation.