India Payroll

Form 138: The Quarterly Salary TDS Return That Replaced Form 24Q

30 Jul 202610 min read
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Form 24Q is gone. From the quarter ended 30 June 2026, the quarterly salary TDS return is Form 138, under the Income-tax Act, 2025 and the Income-tax Rules, 2026. The first return under the new numbering fell due on 31 July 2026.

The due dates did not move and the substance is largely familiar. But this filing matters more than it used to, because of what now hangs off it: Form 130 — the certificate that replaced Form 16 — is generated from your Form 138 data and cannot be prepared manually. Under the old regime a bad Form 24Q produced a mismatch you could chase later. Under the new one it produces a certificate you cannot issue.

Form 138 at a glance
What it isQuarterly salary TDS return
ReplacedForm 24Q, from 1 April 2026
Governing provisions.392 (deduction); s.397 (statements)
First return under new numberingQ1 TY 2026-27, due 31 Jul 2026
FeedsForm 130 certificate, Form 168 statement
Monthly deposit deadline7th of the following month

Position stated as at July 2026. Form numbering and procedural detail are set by the tax authority; confirm the current position before filing.

The due dates

QuarterPeriodForm 138 due
Q11 April – 30 June31 July
Q21 July – 30 September31 October
Q31 October – 31 December31 January
Q41 January – 31 March31 May

Unchanged from Form 24Q. Note the asymmetry that trips up new payroll staff: three quarters get a one-month filing window, and Q4 gets two — because Q4 carries the annual reconciliation that produces the certificates.

What changed, and what did not

OldNew
Salary TDS returnForm 24QForm 138
Non-salary TDS returnForm 26QForm 140
Non-resident TDS returnForm 27QForm 144
TCS returnForm 27EQForm 143
Salary TDS certificateForm 16Form 130
Consolidated tax statementForm 26ASForm 168
TDS on salarys.192s.392
Due dates31 Jul / 31 Oct / 31 Jan / 31 MayUnchanged
Deposit deadline7th of following monthUnchanged
Rates and slabsBudget 2025Unchanged

One consequence worth flagging for finance teams: the TCS return moved to the same 31 July date as Q1, rather than the earlier mid-July date it had as Form 27EQ. If your calendar staggered those two deliberately, it no longer does.

The two annexures

The structure follows the old form's logic. Annexure I goes with every quarterly filing and carries the deductee-wise breakdown — who was paid, how much, how much tax was deducted, against which challan. Annexure II goes with the fourth-quarter filing only, and carries the annual salary detail and tax computation for each employee.

Annexure II is where the certificate comes from. The detailed salary computation that appears in Form 130 is built from it. Which produces the practical rule that most reliably keeps employers out of trouble:

⚠️ Treat the Q4 filing as the certificate run
The old habit was to file Q4 in May and then, separately, generate certificates in June — two exercises, with a chance to fix things in between. That gap has closed. Form 130 is auto-generated from what Annexure II says, and cannot be prepared by hand. Whatever is wrong in the Q4 Annexure II on 31 May is wrong in every certificate on 15 June. Review Annexure II as though you were reviewing the certificates, because you are.

What hangs off this filing

  • Form 130 — the annual salary TDS certificate, generated on TRACES from your filings once Q4 is processed, and issued to each employee by 15 June.
  • Form 168 — the employee's consolidated tax statement, replacing Form 26AS, where the deducted tax appears as credit against their PAN.
  • The employee's return. If the credit is not in Form 168, the employee cannot claim it, and the query comes back to payroll.

The chain runs one way: deposit, then Form 138, then Form 130 and Form 168. Nothing downstream can be better than the return that produced it.

The filing sequence

  1. Deduct TDS on salary monthly under s.392, on the projected annual liability spread over the remaining months.
  2. Deposit by the seventh of the following month, and keep the challan identification details.
  3. Prepare Annexure I for the quarter — deductee-wise deduction and challan mapping.
  4. For Q4, prepare Annexure II — the annual salary and tax computation per employee.
  5. Validate and upload the statement by the due date.
  6. Check for defaults once processed. Defaults appear on TRACES; clear them with a correction statement, paying any shortfall first.
  7. After Q4 is processed, request and download Form 130, and issue it by 15 June.

What lateness and error cost

Three separate exposures, which is why this filing is worth a calendar reminder rather than a habit:

  • Late deposit — interest from the due date until payment.
  • Late filing of the statement — a per-day fee running until the return is filed. Under the 1961 Act this was ₹200 per day, and there was a separate penalty provision for prolonged failure. Confirm the corresponding provisions under the 2025 Act before relying on a figure.
  • Late issuance of the certificate — a per-day, per-certificate penalty. Because it is per certificate, the amount scales with headcount, and a delay of a couple of weeks across a mid-sized workforce becomes material quickly.

The one that hurts most is none of these. It is a defective return that blocks certificate generation in the first week of June, with a 15 June deadline and a correction statement that has to be processed first.

Before you file

  • PAN validation on every employee. An invalid or mismatched PAN breaks the credit and corrupts the pre-filled certificate.
  • Challan reconciliation. Every deduction mapped to a deposited challan, with the right identification details. Unmatched challans are the most common source of defaults.
  • Leavers. Correct employment period for anyone who exited during the quarter, and correct final-settlement TDS.
  • Joiners with previous employment. Where an employee declared prior-employer salary, ensure it is reflected consistently.
  • Regime consistency. The new regime is the default under s.202, and the rebate under s.156 turns on it. An employee taxed on the wrong regime through the year produces a return, a certificate and a personal filing that all disagree.
  • The form number itself. Confirm your software is producing Form 138 and not Form 24Q. This is the error to catch first, and the easiest to overlook.

Common errors

  • Filing Form 24Q out of habit for a Tax Year 2026-27 quarter.
  • Missing the 31 July Q1 deadline because the numbering change was read as a formatting change.
  • Unmatched or wrongly quoted challans, producing short-payment defaults.
  • Invalid PANs, breaking the credit chain to Form 168.
  • Treating Annexure II as a reconciliation exercise rather than as the source of the certificates.
  • Not checking TRACES for defaults after filing, and discovering them in June.
  • Assuming a certificate can be issued manually if the return has a problem. It cannot.

Where a single source of truth pays for itself

Form 138 is a reconciliation between three things that usually live apart: what payroll computed, what was actually deposited, and what the ledger recorded. When those sit in separate systems, the quarterly return is a manual matching exercise every three months — and any mismatch surfaces as a default weeks later. Helion computes salary, TDS and the accounting entry from the same database, so the deductee detail, the challan mapping and the annual computation are read from one record rather than reconciled across three.


This guide reflects the position as at July 2026, under the Income-tax Act, 2025 and the Income-tax Rules, 2026, effective from 1 April 2026. Form numbering, annexure structure, filing procedure and penalty provisions are set by the tax authority and can change; the penalty figures referenced are those that applied under the Income-tax Act, 1961 and the corresponding provisions under the 2025 Act should be confirmed. This is general information for employers, not a substitute for advice from a qualified chartered accountant on a specific situation.