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Only six of 16 transactions under Rule 159 still accept a declaration from a customer without PAN
Under the Income-tax Rules, 2026, Form 97 replaces Form 60 and is accepted for only six of the 16 transactions that require PAN, a dev.to guide reports. Lenders need a transaction-type check at intake before accepting any declaration in place of a PAN.
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Thresholds. Cash deposits or withdrawals of Rs 10 lakh or more in a year: PAN mandatory. Property: PAN above Rs 45 lakh, declaration above Rs 20 lakh. Declaration accepted above Rs 2 lakh per goods or services deal and above Rs 50,000 a year in insurance premium.
- 10 Rs lakh or more Cash deposits/withdrawals in a FY, claim 5 PAN mandatory; no declaration route
- 45 Rs lakh Property: PAN required above, claim 7 Declaration accepted above Rs 20 lakh
- 2 Rs lakh Goods or services, per transaction, claim 23 Declaration accepted above this
- 50,000 Rs Insurance premium in a year, claim 6 Declaration accepted above this
| Figure | Value | Note | Claim |
|---|---|---|---|
| Cash deposits/withdrawals in a FY | 10 Rs lakh or more | PAN mandatory; no declaration route | 5 |
| Property: PAN required above | 45 Rs lakh | Declaration accepted above Rs 20 lakh | 7 |
| Goods or services, per transaction | 2 Rs lakh | Declaration accepted above this | 23 |
| Insurance premium in a year | 50,000 Rs | Declaration accepted above this | 6 |
What happened
- Rule 114B is now Rule 159, the reporting rule 114D is now Rule 160, and the statement of declarations, Form 61, is now Form 98.
- PAN is mandatory with no declaration route for credit card applications, demat account opening and cash deposits or withdrawals of Rs 10 lakh or more in a financial year.
- A declaration is still accepted for opening a bank account other than a time deposit, and for insurance premiums above Rs 50,000 in a year.
- Form 97 asks for more than Form 60 did and runs in six parts, including a masked Aadhaar number and a separate payment-mode code for UPI.
- Declarations received from April to September are reported in Form 98 by 31 October, and those received from October to March by 30 April of the next financial year.
Why it matters
- constraint For the other ten transactions the customer must apply for a PAN, so intake for credit cards, demat accounts and high-value cash has to send a no-PAN applicant to that application and stop.
- cost Taking a Form 97 creates a standing duty to file Form 98 online with the Director of Income-tax (Intelligence and Criminal Investigation) and to keep each declaration for six years from the end of the financial year of the transaction. The guide tells banks to confirm their reporting systems match Form 98.
- contradiction RBI's KYC Directions, as updated on 18 September 2026, still say "Form No. 60 as defined in Income-tax Rules, 1962", so the guide advises lenders to document how their policy maps that wording to Form 97 until RBI aligns it.
- decision Customer scripts and SOPs need to say Form 97 with "formerly Form 60" beside it, because the guide expects customers to keep asking for Form 60 instead of PAN.
Everything here rests on one dev.to guide. By its own account it sets out the changes, the RBI requirements that remain in force, and the steps for checking and tracking customers who have no PAN [20]. It cites the Income Tax Department's rule pages and forms FAQ for the renumbering [18]. The excerpt ends mid-sentence in the reporting section, so the guide's own monitoring steps are not part of it.
The property row shows why one threshold per rule is not enough. A declaration is accepted for immovable property above Rs 20 lakh, and above Rs 45 lakh the person must apply for PAN [7]. That leaves a declaration band Rs 25 lakh wide [24]. Khaitan & Co's April 2026 analysis, which the guide cites, notes that the property trigger moved from Rs 10 lakh to Rs 20 lakh and the hotel bill trigger from Rs 50,000 to Rs 1 lakh [19]. A rule table that still carries the old values will misfire in both directions.
Other rows are cumulative. Cash deposits or withdrawals count once they aggregate Rs 10 lakh or more in a financial year [5]. Time deposits are caught above Rs 50,000, or Rs 5 lakh in aggregate in a year [22]. Insurance premiums are caught above Rs 50,000 in a year [6]. The goods and services row works per transaction, at Rs 2 lakh [23]. A running total needs a key to group by, and PAN is the usual one. A customer without it needs another, so we'd expect lenders to run the totals on an internal customer ID.
The form gives intake a place to enforce the six-row list. Its first part is the coded nature of the transaction, and its last is a signed verification acknowledging prosecution for false statements [9]. In our view, the first field is where the check belongs, before a record is created.
Eligibility turns on who the customer is. Rule 159 takes the declaration from "any person, not being a company or a firm" without PAN [15]. The guide lists individuals, HUFs, trusts, associations of persons, local authorities and certain foreign companies [15]. A minor without taxable income quotes a parent's or guardian's PAN instead [16].
What to watch
- RBI revising its KYC Directions to say Form 97 where they now cite Form No. 60 as defined in the 1962 Rules.
- The first half-yearly Form 98 filings under Rule 160, and whether bank reporting systems match them.
- Any guidance from the Income Tax Department or RBI on tracking the cumulative cash and time-deposit totals for customers without PAN.
Clarity's read
What the record supports and how the coverage leans. The claims behind it follow.
Reality
- Evidence55
- Adoption
- Insufficient
- Hype gap−5
- Incentives40
- Confidence60
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Ranked by verification strength, evidence, and original report placement.
- [1]
Under the Income-tax Rules, 2026, in force from 1 April 2026, Form 60 has been replaced by Form No. 97.
- [2]
Rule 159 lists 16 transactions where PAN must be quoted, and a Form 97 declaration is accepted for only six of them (serial numbers 11 to 16).
- [3]
For the ten transactions where no declaration is accepted, a person without PAN must apply for one.
- [4]
Rule 114B is now Rule 159, Rule 114D is now Rule 160, and Form 61 (statement of declarations received) is now Form No. 98.
ReportedSupportedSource: dev.to guide, citing Income Tax Department rule pages and forms FAQView cited source - [5]
PAN is mandatory with no declaration route for credit card applications and demat account opening, and for cash deposits or withdrawals aggregating Rs 10 lakh or more in a financial year with a bank or post office.
- [6]
A declaration is still accepted for opening a bank account (other than a time deposit) and for insurance premium above Rs 50,000 in a year.
- [7]
For immovable property, a declaration is accepted above Rs 20 lakh; above Rs 45 lakh the person must apply for PAN.
- [8]
Form 97 asks for more than Form 60 did and runs in six parts.
- [9]
The first of Form 97's six parts is the coded nature of the transaction, and the last is a signed verification acknowledging prosecution for false statements.
- [10]
Form 97 identity and address details include a masked Aadhaar number, and UPI now has its own payment-mode code.
- [11]
Under Rule 160, declarations received from April to September are reported in Form No. 98 by 31 October, and declarations received from October to March are reported by 30 April of the next financial year.
- [12]
Declarations must be retained for six years from the end of the financial year of the transaction.
- [13]
Form 98 statements go online to the Director of Income-tax (Intelligence and Criminal Investigation).
- [14]
RBI's KYC Directions, as updated on 18 September 2026, still refer to "Form No. 60 as defined in Income-tax Rules, 1962"; until RBI aligns the wording, the guide says to document how the policy maps it to Form 97.
- [15]
Rule 159 allows the declaration from "any person, not being a company or a firm" without PAN, which the guide says covers individuals, HUFs, trusts, associations of persons, local authorities and certain foreign companies.
- [16]
Minors without taxable income quote a parent's or guardian's PAN instead.
- [17]
The guide says customers will keep asking for "Form 60 instead of PAN", so SOPs should say Form 97 with "formerly Form 60" alongside.
- [18]
The guide cites the Income Tax Department's rule pages and forms FAQ for the mapping of old rules and forms to new ones.
- [19]
Khaitan & Co's April 2026 analysis notes the hotel bill trigger moved from Rs 50,000 to Rs 1 lakh, and the property trigger from Rs 10 lakh to Rs 20 lakh.
ReportedSupportedSource: Khaitan & Co analysis, April 2026, as cited by the dev.to guideView cited source - [20]
The guide says it covers what changed, what RBI still requires, and how to verify and monitor no-PAN customers.
- [21]
The guide says banks should confirm that their reporting systems match Form 98.
- [22]
A declaration is accepted for time deposits above Rs 50,000 or Rs 5 lakh in aggregate in a year.
- [23]
A declaration is accepted for goods or services above Rs 2 lakh per transaction.
- [24]
The declaration band for immovable property is Rs 25 lakh wide.
Sources
1 independent publisher whose own reporting we read for this story.
- dev.toThe PAN Alternative, Its Form 97 Successor and What Lenders Must Verify
1 article · October 12, 2026
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