The NRO account collects every rupee an NRI earns in India — rent, dividends, sale proceeds, pension, redesignated savings interest. Moving that balance back to your foreign country is the most procedure-heavy transaction in NRI banking. FEMA caps it at USD 1 million per financial year. The Income Tax Department gates it behind Form 15CA and, for most large transactions, also Form 15CB. The mechanics confuse even experienced bankers because the form has four distinct Parts (A, B, C, D), and which Part you file depends on whether the income is taxable in India, whether tax has been paid or DTAA-reduced, and the amount thresholds. Get the form wrong and the bank rejects the SWIFT transfer; get it incomplete and the Income Tax Department issues a Section 195 notice; get it late and the planned property closing in your foreign country misses its date. Here is the 2026 step-by-step playbook.
The USD 1 million annual cap
FEMA Regulation 6(2)(d) and the RBI Master Direction on Deposits permit an NRI to repatriate up to USD 1 million per financial year (1 April to 31 March) from NRO account balances. The cap applies to:
- NRO Savings + NRO FD balances
- Sale proceeds of immovable property in India (within the 2-property lifetime limit)
- Sale proceeds of any other Indian assets (mutual funds, shares, bonds)
- Other India-source receipts collected in NRO
The cap resets every 1 April. Two NRIs (e.g., spouses) each have their own USD 1 million cap. A joint NRO with two NRIs has the combined USD 2 million cap allocated to the operations. NRE balances and FCNR balances are fully repatriable without this cap.
The lifetime 2-property repatriation rule
FEMA Regulation 6(2)(c) provides a separate framework for repatriation of sale proceeds of immovable property:
- NRI can repatriate sale proceeds of up to two residential properties in their lifetime without RBI approval — subject to the annual USD 1 million cap above
- Beyond the second property, RBI approval is required
- The 2-property limit applies only to residential property; commercial property + agricultural property (inherited) follow different rules
- Sale proceeds must be credited to NRO first, then repatriated under 15CA / 15CB
Most NRIs use the 2-property limit cleanly. HNI NRIs with multiple Indian properties may need RBI prior approval for the 3rd+ property; engage a CA or banking specialist for these structures.
Form 15CA vs Form 15CB
| Form | Filed by | Purpose |
|---|---|---|
| Form 15CA | Remitter (the NRI account-holder) | Declaration of the remittance + tax position |
| Form 15CB | Chartered Accountant | Independent certificate confirming the tax position + DTAA application |
Form 15CA is mandatory for almost every remittance from NRO to non-resident. Form 15CB is mandatory when the remittance is taxable in India AND exceeds ₹5 lakh in the financial year cumulative (with that single beneficiary). Both forms must be filed online via the income tax portal.
Form 15CA — the four Parts
| Part | When to use | Form 15CB needed? |
|---|---|---|
| Part A | Aggregate remittance to single beneficiary ≤ ₹5 lakh in the FY (whether or not taxable in India) | No |
| Part B | Remittance > ₹5 lakh AND order/certificate u/s 195(2)/195(3)/197 has been obtained from Assessing Officer for lower or nil deduction | No |
| Part C | Remittance > ₹5 lakh AND chargeable to tax in India AND no lower-deduction order — the standard case | Yes — 15CB required |
| Part D | Remittance NOT chargeable to tax in India (foreign-source income; or items on the specified Rule 37BB exempt list) | No |
Part C is the most-frequently-used by NRIs repatriating NRO balance — the funds are India-source interest / rent / capital gain and chargeable to tax, the amount is well above ₹5 lakh, and most NRIs do not pre-obtain a 195(2)/(3) order. Form 15CB by a CA is the standard route.
Specifically when Form 15CB is needed
- Single remittance over ₹5 lakh + chargeable to tax in India + no Assessing Officer order = Form 15CB mandatory.
- Cumulative remittances during the FY exceed ₹5 lakh (any single beneficiary) + chargeable to tax = Form 15CB needed for the excess.
- Property sale proceeds repatriation = always 15CB needed (the gain is chargeable to tax).
- Rental income repatriation = 15CB needed if cumulative > ₹5 lakh.
- Repatriation under the lifetime-2-property limit = 15CB needed.
Form 15CB requires the CA to verify: (a) PAN of remitter, (b) nature of remittance, (c) amount, (d) tax computation including DTAA-rate application if claimed, (e) tax already paid via TDS, (f) net remittance proposed. CA fees for 15CB typically ₹2,500-7,500 per certificate depending on complexity.
Step-by-step online process
- Pre-step — Confirm tax position: is the source of NRO funds chargeable to tax in India? If yes, gather evidence of TDS already deducted, DTAA-reduced rate if applicable (need TRC + Form 10F filed).
- Engage a CA — for Part C transactions. Provide PAN, bank account details, transaction details, source documents.
- Form 15CB filing — CA logs in to incometax.gov.in with their DSC, uploads Form 15CB, signs digitally. Acknowledgement number generated.
- Form 15CA filing — You (or your CA on your behalf via authorised representative login) log in to incometax.gov.in, navigate to e-File → Income Tax Forms → File Income Tax Forms → Form 15CA. Select Part (A/B/C/D). Enter remitter + beneficiary + transaction details. For Part C, link the Form 15CB acknowledgement number. Preview → e-Verify with Aadhaar OTP, Net banking EVC, or DSC.
- Bank submission — Download both 15CA and 15CB acknowledgements as PDF; submit to your Indian bank with the remittance instruction (SWIFT wire to foreign account). Bank verifies and effects the transfer.
- Bank charges — Indian bank typically charges ₹500-2,000 per outward remittance + nominal SWIFT fees + foreign-bank-side handling.
Turnaround: well-coordinated NRO repatriation completes in 3-5 business days from CA engagement to receipt in the foreign account. Rushed or last-minute attempts often slip into a second week due to CA availability + portal queues.
Seven practical scenarios
1. Repatriating NRO interest of ₹3 lakh after TDS
Aggregate < ₹5 lakh in the FY = Part A. No 15CB. NRI files Part A online, submits to bank, receives funds.
2. Repatriating NRO rental income of ₹12 lakh (gross), ₹8.4 lakh after 30% TDS
Amount > ₹5 lakh + chargeable to tax + no lower-deduction order = Part C. Engage CA for 15CB. CA certifies tax computation (₹3.6 lakh TDS deducted; effective tax post-Sec 24(b) deduction reconciled at ITR refund stage). Repatriate ₹8.4 lakh.
3. Repatriating property sale proceeds of ₹1.2 crore (NRI seller, LTCG ₹40 lakh)
Buyer deducted Section 195 TDS at ~20% (or at the Section 197 Lower Deduction Certificate rate). NRI's NRO has ₹1.0 crore (after TDS). Repatriation = Part C (chargeable to tax + above ₹5 lakh). 15CB needed. Within USD 1 million / FY cap (₹1.0 crore ≈ USD 119K at INR 84/USD — fits comfortably). Lifetime 2-property limit applicable.
4. Repatriating NRE interest of ₹15 lakh
NRE interest is exempt from Indian tax under Sec 10(4)(ii) = not chargeable to tax = Part D. No 15CB. NRE balance fully repatriable without USD 1 million cap.
5. Foreign salary credited to NRO by mistake — repatriating back
The salary was foreign-source; should have gone to NRE; incorrectly credited to NRO. Repatriation is reversing the error. Not chargeable to tax (foreign-source for NRI) = Part D. Engage bank operations team to correct the credit; future credits should route to NRE.
6. PMS (Portfolio Management Service) redemption credited to NRO
PMS capital gains are India-source taxable income. Repatriation = Part C with 15CB. Engage CA for the redemption-tax-computation.
7. Pension from a former Indian employer credited to NRO
India-source taxable income. Repatriation of monthly pension amount > ₹5 lakh/year cumulative = Part C. CA can issue an annual 15CB covering the full year's pension (simpler than 12 separate monthly 15CBs).
Rule 37BB exempt list — when 15CA / 15CB are not needed at all
Rule 37BB of the Income Tax Rules lists certain payments where Form 15CA / 15CB is exempted entirely, including:
- Remittances to a specified list of beneficiaries (e.g., the Government, RBI, certain SEBI-registered FPIs)
- Specified categories like donations to certain charitable organisations
- Remittances for which prior RBI approval has been separately obtained
Most NRI personal repatriations are not on this exempt list. Verify with the CA if your specific transaction falls in any exempt category.
Penalty exposure if forms are not filed correctly
- Section 271-I: penalty of ₹1 lakh for non-furnishing or incorrect furnishing of Form 15CA / 15CB
- Section 201: interest at 1% / 1.5% per month on under-deducted tax
- Section 195 + Section 40(a)(i): expense disallowance if TDS not deducted by Indian payer (relevant to Indian-side business making payments to NRI)
- Bank refusal of the SWIFT outward — typically 1-3 day delay until correction
Strategic repatriation planning
- If sale proceeds + accumulated NRO balance > USD 1 million in a single FY: split across two FYs by timing the sale + repatriation.
- For long-term wealth wanting permanent repatriation: prefer NRE-funded asset purchase upstream (NRE-buy = repatriable sale-proceeds without 1M cap).
- For NRO accumulating beyond annual cap: redeploy in Indian-side investments (FDs, MFs) for compounding inside the NRO until repatriation window opens.
- For dual-NRI couples: utilise both individual USD 1 million caps; structure asset ownership accordingly.
Frequently asked questions
Is the USD 1 million cap per FY or per lifetime?
Per financial year (1 April to 31 March). Resets every 1 April. Per individual NRI.
Can I repatriate NRE balance under the 1 million cap?
The USD 1 million cap applies only to NRO. NRE and FCNR are fully repatriable without cap. The Form 15CA Part D applies for NRE repatriation (not chargeable to tax = no cap).
What if I exceeded USD 1 million in a year by mistake?
The bank will refuse the excess transfer. The amount stays in NRO; you can repatriate in the next FY. Substantive over-cap repatriations would need RBI prior approval.
Can my CA issue Form 15CB for a transaction without seeing supporting documents?
Technically possible but professionally negligent. A reputable CA verifies all supporting documents (sale deed, TDS proof, DTAA-rate calculation, Form 10F filed) before issuing 15CB. Always provide complete documentation upfront.
Does the lifetime 2-property limit apply per spouse or per family?
Per individual NRI. A couple has 4 lifetime-property repatriation slots between them (2 per spouse).
Can I repatriate from NRO to my own NRE account (instead of to a foreign account)?
NRO → NRE transfer is also subject to the USD 1 million cap and requires Form 15CA / 15CB. The transfer is treated as a repatriation event (the source money was NRO-taxable; transferring to NRE crystallises the funds as repatriable balance).
Sources: FEMA Regulation 6(2)(c) and 6(2)(d); RBI Master Direction on Deposits; Income Tax Act Section 195; Income Tax Rules Rule 37BB; Form 15CA + 15CB instructions on incometax.gov.in; accessed May 2026. Repatriation procedures change periodically — verify the current process on the income tax portal and bank before initiating. Editorial research, not financial advice.