Form 98 replaces Form 61: reporting no-PAN Form 97 declarations by 31 October under rule 160 of the Income-tax Rules, 2026

The Directorate of Income Tax (Systems) has issued Notification No. 3 of 2026, dated September 2026, which sets out how reporting entities must register and file Form No. 98 under rule 160 of the Income-tax Rules, 2026. Form 98 is the statement that reports every Form No. 97 declaration an entity collects for a transaction listed in the Table in rule 159, and it takes over the job that Form No. 61 did under the Income-tax Rules, 1962.

The first half-yearly deadline under the new rule, 31 October 2026, has just passed. This guide explains what rule 160 requires, how the two filing windows work, what the e-filing portal procedure looks like step by step, and where reporting entities most often slip up. The next due date is 30 April 2027.

What the Section Says

Rule 160 of the Income-tax Rules, 2026 applies to every person referred to in clauses (a) and (b) of its sub-rule (2) who has received a declaration in Form No. 97 for a transaction specified in column 2 of the Table in rule 159. Such a person must furnish a statement in Form No. 98, according to paragraph 1 of Notification No. 3 of 2026. Whether your organisation falls within clause (a) or clause (b) is a question for the rule text itself, so check rule 160(2) before assuming you are in or out.

Paragraph 2 of the notification says the statement must go in through online transmission of electronic data to a server designated for the purpose. Paper filing is not an option. Sub-rule (3) of rule 160 then fixes two deadlines a year, which the table below sets out.

The Director General of Income-tax (Systems) laid down the filing procedure using powers under rule 332 of the 2026 Rules. Paragraph 3(f) states that the notification came into force in September 2026, and that reporting for FY 2025-26 and earlier years, including corrections and deletions, continues under the Income-tax Act, 1961 and the Income-tax Rules, 1962 through Form No. 61, as per Notification No. 2 of 2018 dated 05.04.2018.

That transition rule matters. In practice, an entity may need to run two reporting tracks side by side for some time: Form 61 for declarations tied to FY 2025-26 or earlier, and Form 98 for declarations collected under the 2026 Rules.

The five procedural steps in Notification No. 3 of 2026

Paragraph 3 of the notification breaks the procedure into six sub-paragraphs, (a) to (f). The first five carry the operational steps:

1. Registration and ITDREIN, para 3(a). Log in to the e-filing website with the same login ID used to file the reporting entity's own income tax return. Click "Reporting Portal" under the "Pending Actions" tab. Enter the form type, category and address of the entity, plus the principal officer's details. On submission, the portal generates an ITDREIN (Income Tax Department Reporting Entity Identification Number), and the principal officer gets a confirmation e-mail and SMS. Once generated, an ITDREIN cannot be deactivated.
2. Submission, para 3(b). Download the prescribed schema, the Report Generation and Validation Utility and the Generic Submission Utility from the "Resources" tab of the Reporting Portal. Prepare the statement, digitally sign it, and upload it on the Reporting Portal or through the Generic Submission Utility using the principal officer's PAN and password.
3. Correction, para 3(c). If the entity finds an error, or the department sends defects through a Data Quality Report (DQR), file a correction statement. The DQR file is downloaded from the DQR column under the "Statements" tab and opened in the Report Generation Utility. Defects must be fixed until "Reports Requiring Correction (RRC)" reaches zero within the specified period.
4. Deletion, para 3(d). Reports filed by mistake are removed by choosing the statement type "Deletion Statement" and filing all such reports in one statement, with exactly the previously filed values in every field.
5. Security and archival, para 3(e). The entity must document and implement information security policies, and archival and retrieval procedures, so that submitted information is available promptly to the competent authorities.

Entities already registered for Form No. 61 do not need to register again. Under paragraph 3(a), the existing ITDREIN and principal officers stay valid, and for verifying Form 98 the principal officer acts as the "Designated Director".

Worked Example

Take a hypothetical co-operative bank that already holds an ITDREIN from its Form 61 filings. Its principal officer has a PAN-based login on the e-filing portal. The figures below are illustrative only and are chosen to show how the two deadlines and the correction cycle interact.

Between 1 April 2026 and 30 September 2026, the bank's branches collect 240 Form 97 declarations for transactions covered by the Table in rule 159. Under rule 160(3)(a), all 240 must be reported in a Form 98 statement by 31 October 2026. Because the bank was registered for Form 61, it uses the same ITDREIN and skips fresh registration, as paragraph 3(a) allows.

The compliance team downloads the Report Generation and Validation Utility from the "Resources" tab, keys in the 240 reports, and the principal officer digitally signs and uploads the file on 24 October 2026, seven days before the due date. A week later the bank receives a DQR showing an RRC count of 18. The team opens the DQR in the utility, fixes the 18 records, and files a correction statement. The next DQR shows RRC at 3; a second correction brings it to 0.

The team also finds that 4 reports were uploaded twice. It files one Deletion Statement containing those 4 reports, each with the exact values originally submitted, as paragraph 3(d) requires.

Separately, the bank still holds 15 declarations relating to FY 2025-26 that were never reported. Under paragraph 3(f), those go through Form No. 61 under Notification No. 2 of 2018, not through Form 98.

The bank then logs a further 190 declarations between 1 October 2026 and 31 March 2027. Under rule 160(3)(b), those are due in Form 98 by 30 April 2027. That gives a full-year total of 430 declarations reported across two Form 98 statements, plus the correction and deletion statements needed to clean them.

For staff who also handle withholding on the same customers, our TDS calculator and the TDS glossary entry explain how deductions flow into the customer's Form 26AS and Annual Information Statement.

Common Mistakes

1. Filing FY 2025-26 declarations in Form 98. Paragraph 3(f) is explicit that FY 2025-26 and earlier years, including corrections and deletions, stay on Form No. 61 under Notification No. 2 of 2018. Sending a 2025-26 declaration through the Form 98 utility puts it on the wrong track.

2. Re-registering an entity that already has an ITDREIN. Paragraph 3(a) says entities registered for Form 61 do not need to register for Form 98. Because an ITDREIN cannot be deactivated once generated, creating a duplicate registration leaves a permanent second identifier on record.

3. Using the wrong login. Registration uses the login ID of the reporting entity's own income tax return. Upload of the statement uses the principal officer's PAN and password. Mixing up the two, which happens often when a new compliance officer joins after 30 September, holds up filing close to a 31 October or 30 April deadline.

4. Treating the first upload as the finish line. Under paragraph 3(c), the job is done only when RRC is zero within the specified period. A statement filed on 31 October with an RRC of 18 against it is not a clean filing, and it needs a correction statement.

5. Correcting instead of deleting, or deleting with altered values. A report filed by mistake needs a Deletion Statement under paragraph 3(d), and every field must carry exactly the values first filed. A Deletion Statement with even one edited field may not match the original record.

6. Skipping the paperwork on security and archival. Paragraph 3(e) requires the entity to document and implement information security and archival policies with defined roles. The obligation exists even if every statement is filed on time, so keep written policies on file.

7. Missing the April window because October is over. With 31 October 2026 behind us, the next due date is 30 April 2027 for declarations received by 31 March 2027. Teams that relax after the first window often find March volumes are the largest of the year.

FAQ

What is Form 98 under the Income-tax Rules, 2026?

Form No. 98 is the statement that a person referred to in clauses (a) and (b) of rule 160(2) must file after receiving Form No. 97 declarations for transactions listed in the Table in rule 159. Notification No. 3 of 2026 sets the filing procedure.

What are the due dates for filing Form 98?

Under rule 160(3), declarations received by 30 September must be reported by 31 October of that year. Declarations received by 31 March must be reported by 30 April of the following financial year.

Do entities registered for Form 61 need a new ITDREIN?

No. Paragraph 3(a) of Notification No. 3 of 2026 says entities already registered for Form No. 61 need not register for Form 98, and their existing ITDREIN and principal officers remain valid.

Who verifies Form 98?

For verification of Form No. 98, the principal officer acts as the "Designated Director", per paragraph 3(a). The statement is digitally signed and uploaded using the principal officer's PAN and password, per paragraph 3(b).

How do I fix errors in a filed Form 98 statement?

File a correction statement. Download the Data Quality Report from the "Statements" tab, open it in the Report Generation Utility, fix the defects, and repeat until "Reports Requiring Correction (RRC)" is zero within the specified period.

Can an ITDREIN be cancelled?

No. Paragraph 3(a) states there is no option to deactivate an ITDREIN once it is generated.

Where do FY 2025-26 declarations go?

Reporting for FY 2025-26 and earlier years, including corrections and deletions, continues through Form No. 61 under the Income-tax Act, 1961, the Income-tax Rules, 1962 and Notification No. 2 of 2018 dated 05.04.2018.

Source: Directorate of Income Tax (Systems), CBDT, Notification No. 3 of 2026 (September 2026). Readers can check their wider tax position with our income tax calculator and compare regimes with the old vs new regime tool. This article explains a procedure; it is not legal advice, and reporting entities should confirm coverage under rule 160(2) against the official rule text.