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Guide

EPF withdrawal TDS: How Form 121 compares with Forms 15G and 15H

By TheFinanceBase Team 9 min read

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For a tax year beginning on or after 1 April 2026, Form 121 replaces Forms 15G and 15H. It is a declaration that your estimated tax liability for the relevant year is nil; it is not an exemption certificate that automatically makes an EPF withdrawal tax-free. Whether your recognised provident-fund withdrawal is taxable still depends mainly on your service period, continuity and the applicable tax rules.

What changes from 1 April 2026?

The form name changes because the legal framework changes. Forms 15G and 15H belonged to the Income-tax Act, 1961 framework. For tax years beginning on or after 1 April 2026, the Income-tax Act, 2025 and Income-tax Rules, 2026 provide a single declaration, Form 121, under section 393(6) and (7) and Rule 211, as described by the Income Tax Department and EPFO transition material.

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That means the practical question for the 2026–27 tax year is no longer “Should I file 15G or 15H?” It is “Am I eligible to submit Form 121, and is my EPF payment otherwise taxable?” For an earlier tax year governed by the 1961 Act, the old forms remain the relevant names.

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Issue Forms 15G and 15H Form 121
Legal framework Income-tax Act, 1961, section 197A and Rule 29C Income-tax Act, 2025, section 393(6)/(7) and Income-tax Rules, 2026, Rule 211
Form structure Two declarations divided by age and eligibility category One unified declaration
Age naming 15G generally applied to eligible individuals below 60; 15H to eligible resident individuals aged 60 or more Both age groups use Form 121, although age still affects eligibility conditions
Core declaration Request for non-deduction where the statutory conditions were met Declaration that estimated total tax liability for the relevant tax year is nil, subject to the rules
EPF relevance Could cover eligible EPF withdrawal cases under the old framework Recognised provident-fund accumulated balances are expressly listed among covered specified payments
Effective point Earlier tax years under the 1961 Act Tax years beginning on or after 1 April 2026

Is Form 15G still valid for EPF withdrawal?

For a tax year beginning on or after 1 April 2026, use Form 121 rather than Form 15G or Form 15H. The old forms are part of the earlier Act’s framework and should not be treated as the current declaration for a 2026–27 payment merely because your age would previously have put you in the 15G or 15H category.

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For a payment relating to an earlier tax year, the governing law and the date on which the income is credited or paid matter. Do not backdate a Form 121 or assume that a declaration filed for one tax year automatically carries into another. If the payment straddles an accounting or tax-year boundary, ask the EPF payer or a tax professional which year’s procedure applies before submitting anything.

What Form 121 actually does

The Income Tax Department’s official FAQ defines Form 121 as “a statutory declaration prescribed under the Income-tax Rules, 2026, through which a taxpayer declares that tax liability on its estimated total income for the relevant tax year is nil.” The declaration is made to the payer so that withholding can be considered under the applicable provisions.

For EPF, the payer is identified in the FAQ as the trustees of the EPF Scheme or a person authorised under that scheme to make the accumulated-balance payment. Form 121 can therefore affect the amount deducted at source when the EPF payment is made. It does not decide the final tax character of the withdrawal.

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  • TDS: tax collected in advance by the payer at the time of payment or credit.
  • Final taxability: whether the withdrawal belongs in your taxable income, after applying the rules to your service history, continuity, exemptions and other facts.
  • Form 121: a declaration about estimated tax liability and eligibility for non-deduction; it is not a blanket exemption for EPF withdrawals.

If your withdrawal is taxable under the applicable rules, filing a declaration does not convert it into exempt income. A declaration that is inaccurate can also create compliance problems, so do not submit it simply because you want the full amount released.

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Who can submit Form 121?

The official FAQ describes eligibility in terms of age, residence or taxpayer category, estimated total income and estimated tax liability. For individuals below age 60 and other eligible persons, the stated conditions include nil estimated tax liability for the tax year and specified income not exceeding the maximum amount not chargeable to tax. For an individual aged 60 or more, the FAQ states the condition as nil tax on estimated total income.

The EPFO implementation material states that resident taxpayers in both age groups use Form 121. The Income Tax Department FAQ excludes companies, firms and non-residents from the eligible group. Those categories should not assume that an individual’s declaration is available to them.

Age determines which conditions apply; it does not revive the old 15G/15H labels after the transition. Read the current Form 121 itself and the rules for your taxpayer category, especially if you have income from salary, interest, rent, capital gains, business activity or more than one payer.

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How to submit Form 121 for an EPF payment

  1. Identify the tax year. Check whether the relevant tax year begins before or on/after 1 April 2026. That determines whether the old 1961 Act forms or Form 121 is the applicable declaration framework.
  2. Check your taxpayer category. Confirm that you are an eligible resident individual or other eligible person. Companies, firms and non-residents are not covered by the individual eligibility described in the official FAQ.
  3. Estimate your total income and tax. Include all relevant income for that tax year, not just the EPF amount. Form 121 requires a nil estimated tax liability, subject to the age-specific conditions.
  4. Check the EPF payment type. The FAQ specifically includes recognised provident-fund accumulated-balance payments among the specified categories. An account transfer is not the same event as a cash withdrawal.
  5. Use the current form. For a tax year beginning on or after 1 April 2026, complete Form 121 rather than uploading an old 15G or 15H template.
  6. Submit it to the payer. The official guidance says to submit before the income is credited or paid, through the payer’s electronic portal or in paper form, and separately to each payer.
  7. Keep evidence. Save the submitted declaration, acknowledgement, payment statement and service-history records. They help reconcile any TDS credit and support your return if the withdrawal is questioned.

Submitting after the EPF amount has already been credited may not reverse a deduction. The payer’s portal and processing timetable can also control whether a declaration is accepted for that payment.

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Will an EPF withdrawal be taxable after less than five years?

The official retirement-benefit guidance says that a recognised provident-fund withdrawal after five years is exempt, while a withdrawal before five years can be taxable. “Five years” is not a mechanical answer in every case: continuity of service, transfers between recognised provident-fund accounts and specified termination circumstances can affect the result.

Before deciding whether to file a declaration, assemble the facts that determine the five-year test:

  • Joining and exit dates for every employer whose recognised provident-fund balance is involved.
  • Whether the balance was transferred when you changed jobs rather than withdrawn.
  • Whether service was continuous for the relevant purpose.
  • Why employment ended, including circumstances outside your control where an exception may apply.
  • Whether the payment is a final cash withdrawal, a transfer or another permitted settlement.

An older EPFO flowchart lists no TDS in situations including transfer to another PF account, withdrawal after five years and certain terminations beyond the member’s control. That flowchart is historical context, not a substitute for the current law. Verify any exception against the rules applicable to your payment date.

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Is TDS deducted on an EPF withdrawal above ₹50,000?

Under the currently displayed section 192A text of the Income-tax Act, 1961, the rate for a taxable recognised-provident-fund accumulated-balance payment is 10%, and no deduction is made where the payment or aggregate payment is less than ₹50,000. Those figures describe the 1961 Act framework and should be read with that qualification.

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Point What the official material establishes How to use it
Rate 10% for a taxable recognised-provident-fund accumulated-balance payment under the displayed section 192A text of the 1961 Act Apply only when the payment is governed by that framework
Threshold No deduction where the payment or aggregate payment is less than ₹50,000 under that displayed text Do not treat a payment above the threshold as automatically taxable; the underlying withdrawal must first be taxable
Older EPFO figure An older flowchart shows ₹30,000 That is historical and superseded; it is not today’s threshold under the displayed section 192A text
2025 Act transition The reviewed Form 121 FAQ confirms the form change but does not fully establish the corresponding post-transition EPF rate, threshold and PAN treatment Do not extrapolate the 1961 Act figures to every Form 121 payment without checking the current law or payer instructions

Therefore, the answer to “Is TDS deducted above ₹50,000?” is conditional. Under the displayed 1961 Act section 192A text, a taxable payment or aggregate payment at or above the stated threshold can fall within TDS. A payment that is exempt because the five-year and exception rules are satisfied is a different case. For payments under the 2025 Act framework, confirm the current rate, threshold and PAN requirements rather than relying on the old figures.

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Can Form 121 be used to avoid TDS on PF withdrawal?

It can support non-deduction only when you meet the declaration’s conditions, including the nil estimated tax-liability requirement and the relevant category rules. It is not a way to avoid TDS merely because the withdrawal is inconvenient to tax or because the amount is needed urgently.

Use this decision sequence:

  1. Is the tax year on or after 1 April 2026? If yes, consider Form 121; if no, the earlier framework may apply.
  2. Is the withdrawal itself exempt? A recognised-PF withdrawal after five years is generally described as exempt, subject to continuity and applicable exceptions.
  3. If potentially taxable, is your estimated total tax liability nil? If not, do not sign Form 121.
  4. Does the payment meet the applicable TDS threshold and other statutory conditions? For the 1961 Act, section 192A displays the ₹50,000 threshold and 10% rate; the post-transition details require current confirmation.
  5. Can you document the answer? Keep service, transfer, income and declaration records before asking the payer to rely on the form.

Common mistakes and how to fix them

Submitting 15G or 15H for a 2026–27 payment

Use Form 121 for a tax year beginning on or after 1 April 2026. If an EPFO portal still displays an old label, pause and obtain written clarification from the payer or an adviser rather than submitting an obsolete declaration.

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Assuming “no TDS” means “no tax”

TDS is collection at source. Reconcile the payment with your income-tax return and determine final taxability separately.

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Counting five years without checking transfers

Gather records from all employers and verify whether PF balances were transferred. A short period with the latest employer may not describe the full recognised-PF service history.

Quoting the ₹30,000 threshold

The older EPFO flowchart is not current threshold guidance. The displayed 1961 Act section 192A text states ₹50,000, while the post-2026 framework’s complete EPF TDS details are not established by the reviewed FAQ.

Submitting one declaration to several payers

The official FAQ says to submit separately to each payer. An EPF trustee or authorised scheme person is the payer for the recognised-PF accumulated-balance payment.

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Filing after payment

Submit before income is credited or paid. A later declaration may not undo TDS already processed; instead, retain the tax deduction statement and claim eligible credit or refund through the return process.

What to do if the new rules are unclear

The Form 121 transition is clear at the form level, but the reviewed official material does not conclusively state every post-transition EPF TDS detail, including the exact rate, threshold and PAN treatment under the Income-tax Act, 2025 and Rules, 2026. Do not fill that gap by copying the 1961 Act figures into every 2026–27 case.

For a straightforward case, ask the EPF payer which current form and withholding rule its system applies, and retain the response. Individual advice is sensible when you have several employers, transferred balances, a break in service, overseas or non-resident status, multiple income sources or uncertainty about your estimated tax liability. A qualified Indian tax professional or chartered accountant can review those facts; the declaration should still be filed with the EPF payer, not with an unrelated intermediary.

Practical checklist before you submit

  • Tax year identified and transition date checked.
  • Current form confirmed: Form 121 for tax years beginning on or after 1 April 2026.
  • Resident and taxpayer-category eligibility checked.
  • Estimated total income and tax calculated, including non-EPF income.
  • Service dates, transfers and termination reason documented.
  • Withdrawal distinguished from PF transfer.
  • Current payer identified and declaration submitted separately to each payer before credit or payment.
  • Submission acknowledgement and TDS records saved.
  • 1961 Act figures not assumed to govern every post-transition payment.

The answer in one sentence

For a tax year beginning on or after 1 April 2026, Form 121 replaces Forms 15G and 15H for eligible taxpayers, but it only addresses withholding eligibility: whether your EPF withdrawal is ultimately taxable still turns on the recognised-PF rules, especially the five-year service test, continuity and applicable exceptions.

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