What are Form 97 and Form 98?

Under the Income-tax Rules, 2026, Form 97 is the declaration given by a person without a PAN (earlier Form 60), and Form 98 is the statement of those declarations filed online by the person who received them (earlier Form 61).

When is Form 98 due for April to September 2026?

Declarations received by 30 September must be reported by 31 October of that year (rule 160(3)(a)), so 31 October 2026, a Saturday. Declarations received by 31 March are reported by 30 April of the next financial year.

Does a hotel or jeweller client have to file Form 98?

Businesses at Sl. Nos. 15 and 16 of the rule 159 table (cash bills over Rs 1 lakh at hotels, restaurants, banquet halls, convention centres, event managers; other sales over Rs 2 lakh per transaction) file only if their accounts must be audited and they received a Form 97.

Form 98 (old Form 61) sheet for CA firms: which clients must report Form 97 non-PAN declarations for April–September 2026 by 31 October

Updated 22 Oct 2026 · Disclosure: the white-label calendar linked below is an Unadhi product (₹999/year).

What you get: a ready-to-copy Google Sheet layout in two tabs. Tab "declarations" logs every Form 97 (old Form 60) a client received and works out, by formula, whether it was needed and which statement it goes in. Tab "clients" has one row per client and tells you, by formula: "Not covered by rule 160", "No Form 97 received", "Register on Reporting Portal first", "File Form 98 by 31 Oct", "Fix N RRC" or "Done", plus a days-left flag. Also a nine-day plan, three made-up example rows and two client messages. Free, no sign-up.

Short answer (checked 22 Oct 2026): under the Income-tax Rules, 2026, the non-PAN declaration Form 60 is now Form 97 and the half-yearly statement Form 61 is now Form 98. A person covered by rule 160 who received any Form 97 declaration between 1 April and 30 September must file Form 98 online by 31 October (rule 160(3)(a)); declarations received by 31 March go by 30 April. For this half-year that means 31 October 2026, a Saturday. Covered persons are those in column 4 of the rule 159 table at Sl. Nos. 11 to 14, and at Sl. Nos. 15 and 16 only if their accounts must be audited (rule 160(2)). Form 97 itself must be kept for six years from the end of the financial year (rule 160(1)(b)). Sources: Rule 159 and Rule 160 (Income Tax Department) and the Directorate of Income Tax (Systems) Notification No. 3 of 2026 (15 September 2026). This is a starting point, not tax advice.

Which clients this is about

Rule 159 Sl. No.	Transaction (value)	Who receives the Form 97	Form 98 needed?
11	Purchase, sale, gift or joint development agreement of immovable property (over ₹20 lakh, or stamp value over ₹20 lakh)	Registrar / Sub-Registrar	Yes (government office, rarely a CA client)
12	Opening a bank account (other than a time deposit or Basic Savings Bank Deposit Account)	Banking company or co-operative bank	Yes
13	Time deposit over ₹50,000, or more than ₹5 lakh in a year	Bank, co-operative bank, post office, Nidhi, deposit-taking NBFC	Yes: check co-operative bank, Nidhi and NBFC clients
14	Account-based relationship with an insurer, premium over ₹50,000 in a year	Insurer	Yes
15	Cash payment over ₹1 lakh against a bill to a hotel, restaurant, convention centre, banquet hall or event manager	The business issuing the bill	Only if the client's accounts must be audited
16	Sale or purchase of any other goods or services over ₹2 lakh per transaction	The business issuing the bill (for example a jeweller or a furniture or electronics dealer)	Only if the client's accounts must be audited

Form 97 is given by a person who is not a company or firm and has no PAN (rule 159(2)(b)). If every customer quoted a PAN, there is no Form 97 to report.

Tab "declarations": one row per Form 97 received

Col	Header	What goes in
A	Date received	Date on the Form 97
B	Client	Exactly as in tab "clients" column A
C	Sl. No.	11 to 16 from the table above
D	Customer	Name on the Form 97 (keep the sheet private)
E	Amount ₹	Value of the transaction
F	Paid in cash?	Yes / No (matters for Sl. No. 15)
G	Form 97 needed?	Formula below
H	Goes in	Formula below
I	Original kept until	Formula below (six years from end of the financial year)

G2: =IF(A2="","",IF(C2=15,IF(AND(F2="Yes",E2>100000),"Yes","No: below ₹1 lakh cash"),IF(C2=16,IF(E2>200000,"Yes","No: ₹2 lakh or less"),"Yes (check rule 159 limit)")))

H2: =IF(A2="","",IF(A2<DATE(2026,4,1),"FY 2025-26 or earlier: Form 61 (1962 Rules)",IF(A2<=DATE(2026,9,30),"Form 98 by 31 Oct 2026","Form 98 by 30 Apr 2027")))

I2: =IF(A2="","",DATE(YEAR(A2)+IF(MONTH(A2)>=4,7,6),3,31))

The "Form 61" line is from point (f) of Notification No. 3 of 2026: reporting for FY 2025-26 and earlier, including corrections and deletions, stays under the 1961 Act and 1962 Rules through Form 61.

Tab "clients": one row per client

Col	Header	What goes in
A	Client	Name
B	Sl. No.	Main rule 159 serial for this client (11 to 16), or 0 if none
C	Accounts audited?	Yes / No
D	Form 97s Apr–Sep 2026	`=COUNTIFS(declarations!B:B,A2,declarations!H:H,"Form 98 by 31 Oct 2026",declarations!G:G,"Yes*")`
E	ITDREIN?	Yes / No (Reporting Portal registration)
F	Form 98 filed on	Date
G	Acknowledgement no.	From the Reporting Portal
H	Open RRC	"Reports Requiring Correction" shown on the portal
I	Status	Formula below
J	Days left	Formula below

I2: =IF(A2="","",IF(OR(B2<11,B2>16),"Not covered by rule 160",IF(AND(B2>=15,C2<>"Yes"),"Not covered: accounts not audited",IF(D2=0,"No Form 97 received",IF(E2<>"Yes","Register on Reporting Portal first",IF(F2="","File Form 98 by 31 Oct",IF(H2>0,"Fix "&H2&" RRC","Done")))))))

J2: =IF(OR(A2="",F2<>"",D2=0),"",IF(TODAY()>DATE(2026,10,31),"Past 31 Oct",DATE(2026,10,31)-TODAY()&" days left"))

Three made-up example rows

Client	Sl. No.	Audited?	Form 97s	ITDREIN?	Status
Example banquet hall	15	Yes	4	Yes	File Form 98 by 31 Oct
Example jeweller (first year above audit limit)	16	Yes	2	No	Register on Reporting Portal first
Example restaurant	15	No	1	No	Not covered: accounts not audited

How filing works (Notification No. 3 of 2026)

Register once: log in to the e-filing portal with the client's own login, open "Pending Actions" → "Reporting Portal", enter form type, category, address and principal officer. An ITDREIN is generated and cannot be deactivated. Clients already registered for Form 61 keep their ITDREIN and principal officer; no new registration.
Prepare and upload: download the Form 98 schema, Report Generation and Validation Utility and Generic Submission Utility from the "Resources" tab of the Reporting Portal. The statement is digitally signed and uploaded by the principal officer (PAN login).
Fix errors: if the Data Quality Report shows "Reports Requiring Correction", file a correction statement until the count is zero.
Wrong report filed: file a "Deletion Statement" with the exact values filed earlier.

Nine-day plan (22–31 October 2026)

Thu 22 – Fri 23 Oct: fill column B and C for every client with hotel, restaurant, banquet, event, jewellery, high-value retail, co-operative bank, Nidhi or NBFC business. Send message 1.
Sat 24 – Mon 26 Oct: log every Form 97 in tab "declarations"; check column G so only needed declarations are reported.
Tue 27 Oct: register any client showing "Register on Reporting Portal first"; confirm the principal officer's DSC works (message 2).
Wed 28 – Fri 30 Oct: prepare, validate and upload Form 98; write the acknowledgement number in column G. 31 October is a Saturday, so aim to finish by Friday.
After upload: check the Data Quality Report and clear any RRC.

Two client messages

1. Data request: "Please send us copies of every Form 97 (earlier called Form 60) your staff collected from customers without a PAN between 1 April and 30 September 2026, with the bill number and amount for each. The statement (Form 98) is due by 31 October 2026. If you collected none, please reply 'none' so we can record it."

2. Signing: "The Form 98 statement has to be digitally signed by your principal officer. Please confirm whose DSC we should use and that it is valid until at least 31 October 2026."

Notes

Rule 160 applies to a person who "has received any declaration in Form No. 97". We did not find a rule requiring a nil statement; confirm on the Reporting Portal before deciding not to file.
Penalties and late fees are not covered here; check them in the Act before advising a client who missed the date.
Declarations received in FY 2025-26 or earlier stay on Form 61 under the 1962 Rules (Notification No. 3 of 2026, point (f)).
The sheet holds customer names and amounts: share it only inside your firm.

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