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Do I need a CA to verify Form 44?

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Short answer

Only in two cases. Rule 76(16) of the Income-tax Rules, 2026 requires Form No. 44 to be verified by an accountant where the person claiming credit is a company, or, for anyone else, where the foreign tax paid outside India for the tax year equals or exceeds ₹1,00,000.1 A sole-proprietor freelancer with less foreign tax than that can file Form 44 without accountant verification; Form 67, which it replaced from tax year 2026-27, had no such requirement in rule 128.12

Foreign tax credit lets a resident set tax withheld abroad against Indian tax on the same income. For income earned from 1 April 2026 (tax year 2026-27), the claim is made in Form No. 44 under rule 76 of the Income-tax Rules, 2026, which replaced Form 67 under rule 128 of the 1962 Rules.12 Rule 76 added an accountant verification requirement that did not exist before.

When must Form 44 be verified by an accountant?

Rule 76(16) says Form No. 44 shall be verified by an accountant defined in section 515(3)(b) of the Income-tax Act, 2025:1

  1. where the assessee is a company; or1
  2. in all other cases, where the amount of foreign tax paid outside India for a tax year equals or exceeds ₹1,00,000.1

How does this apply to different exporters?

The table applies rule 76(16) to common cases in tax year 2026-27.1

WhoForeign tax for the yearVerification needed?
Freelance UX designer (individual)₹40,000No
Freelance data consultant (individual)₹1,20,000Yes
Design studio run as an LLP₹60,000No
Software agency run as a private limited company₹15,000Yes, because it is a company

Remember that the threshold counts foreign tax paid, not the credit you finally get. A consultant whose credit is capped at ₹80,000 still needs verification if ₹1,20,000 was withheld.1

How do I work out whether I cross ₹1,00,000?

Add up the tax withheld or paid abroad during the tax year across all clients and countries, converting each amount at the telegraphic transfer buying rate on the last day of the month before it was deducted, as rule 76(7)(b) requires.1 Keep the withholding certificate or statement for each deduction, because rule 76(10) and (11) require it with the claim.1

What else changed from Form 67?

Rule 128 required Form 67 by the end of the relevant assessment year and did not require accountant verification.2 Rule 76 requires Form 44 within twelve months from the end of the tax year, and introduces Form No. 45 for reporting settlement of disputed foreign tax, which must also be verified where the related Form 44 was.1 The full comparison is in Form 44 replaces Form 67.

If you are close to the threshold, count your foreign tax well before 31 March so that a chartered accountant (CA) can be engaged in time.1

How did we verify this?

We checked this page against the sources below on 28 October 2026. Read our methodology or report an error.

  1. [1]Income-tax Rules, 2026, rule 76 (Foreign tax credit, Form Nos. 44 and 45) (Income Tax Department)
  2. [2]Income-tax Rules, 1962, rule 128 (Foreign Tax Credit, Form No. 67) (Income Tax Department)

Frequently asked questions

Is the ₹1,00,000 test per client or per year?+

Per tax year. Rule 76(16)(b) looks at the amount of foreign tax paid outside India for a tax year, so add up tax withheld by all foreign clients and platforms.1

Does an LLP or partnership firm need verification?+

Only companies need it regardless of amount. An LLP, firm or individual needs it when foreign tax for the tax year is ₹1,00,000 or more.1

Which rupee value do I use for the ₹1,00,000 test?+

Rule 76(7)(b) converts foreign tax at the telegraphic transfer buying rate on the last day of the month before the month in which it was deducted, so use those converted figures.1

Does Form 45 also need verification?+

Yes, where the Form 44 for that tax year had to be verified. Form 45 reports settlement of disputed foreign tax.1

This page is general information for Indian service exporters, not tax or legal advice. Rules change and outcomes depend on your facts, so confirm with a chartered accountant before acting.