DIFFICULTIES IN FILLING COLUMN 11 OF FORM 121

DIFFICULTIES IN FILLING COLUMN 11 OF FORM 121

Form 121 is a self-declaration form used to request banks and financial institutions not to deduct Income Tax at Source (TDS) on certain incomes (like interest or dividends). Taxpayers submit it to declare that their total estimated income for the financial year is below the taxable limit.

Effective from April 1, 2026, Form 121 replaced the older, separate Form 15G (for non-senior citizens) and Form 15H (for senior citizens). It can be filed by eligible resident individuals and Hindu Undivided Families (HUFs)

OTHER FORMS 121 FILED EARLIER

While filing Form 121, you also have to specify the relevant information about other such forms filed by you, if any, for the same financial year in Column № 11. This information was to be provided previously in Forms 15G/15H also and there is no change in it. However, this is very complicated and it should have been deleted in Form 121 if they really wanted any simplicity or improvement in the system. A detailed discussion is required on this. Let us take the following example:

I have fixed deposits in 4 banks. The interest amounts expected to be paid to me by these banks on these deposits during the financial year are given below:

Bank A: Rs. 60,000/-

Bank B: Rs. 70,000/-

Bank C: Rs. 80,000/-

Bank D: Rs. 90,000/-

I am below 60 years. I do not have any other income. Therefore, my estimated income during the financial year will be less than Rs. 4 Lakhs and I am entitled to file Form 121. If I do not file Form 121, all the banks will deduct 10% income tax at source from my payments since all the interest amounts are more than Rs. 50,000/-. I will, therefore, have to submit four 121 forms, one to each bank. How to fill them?

As per the requirements of Form 121, I have to furnish following data in each of these forms:

Column 10. Estimated income for which this declaration is being made

Column 11(a). Total number of Form № 121 filed earlier

Column 11(b). Aggregate amount of income for which Form № 121 filed earlier

Column 12. Aggregate amount of income for which declaration is made during the tax year [sum of column 10 and 11(b)]

It is easy to fill column 10. The expected interest amount can be specified in this column. It will be Rs. 60,000/- for Bank A, Rs. 70,000/- for Bank B, and so on. However, how to fill other columns in the forms. The information to be supplied in a form is relative to other forms. What I write in Form 121 for Bank B is relative to the information I gave in Form 121 for Bank A. And the information I give in the Form 121 for Bank C is relative to what I wrote in these forms submitted to Banks A and B, and so on.

Let us assume that I am filling all the four forms at the same time which will normally be the case for most of us. I do not know how other people do it, but I do it in the following way:

I plan that I will submit the forms to the banks in the following order:

1. Bank A

2. Bank B

3. Bank C

4. Bank D

Then I will give following information to Bank A:

Column 11(a). Total number of Form № 121 filed earlier — Nil

Column 11(b). Aggregate amount of income for which Form № 121 filed earlier — Nil

Column 12. Aggregate amount of income for which declaration is made during the tax year [sum of column 10 and 11(b)] — Rs. 60,000/-

Details for Bank B:

Column 11(a). Total number of Form № 121 filed earlier — 1

Column 11(b). Aggregate amount of income for which Form № 121 iled earlier — Rs. 60,000/-

Column 12. Aggregate amount of income for which declaration is made during the tax year [sum of column 10 and 11(b)] — Rs. 1,30,000/-

Details for Bank C:

Column 11(a). Total number of Form № 121 filed earlier — 2

Column 11(b). Aggregate amount of income for which Form № 121 filed earlier — Rs. 1,30,000/-

Column 12. Aggregate amount of income for which declaration is made during the tax year [sum of column 10 and 11(b)] — Rs. 2,10,000/-

Details for Bank D:

Column 11(a). Total number of Form № 121 filed earlier — 3

Column 11(b). Aggregate amount of income for which Form № 121 filed earlier — Rs. 2,10,000/-

Column 12. Aggregate amount of income for which declaration is made during the tax year [sum of column 10 and 11(b)] — Rs. 3,00,000/-

Appears simple? No, it is not. First of all, writing different information in different forms at the same time is prone to errors. Any time there may be some mix-up of the data in various forms and I will be giving incorrect data to the IT Deptt.

Secondly, I may not be able to submit the forms to various banks in the same order in which I had initially planned. Some banks accept a scanned copy of the form by e-mail which is faster, some banks are near my residence and I can personally visit them and submit a hard copy which takes a little more time, and to some banks, which are distant, I need to send the forms by post which is time-consuming. However, if the order of submission of the forms to various banks gets changed due to these issues, then a lot of the data which I specified in the forms may become wrong and I am liable to be punished for that.

One way to avoid this trouble is that I specify in Column 11(a) that I have previously submitted 3 forms (though it is not correct) in all the 4 forms. But in Column 11(b), the income amount will still be different. It will be Rs. 2,40,000/- for Bank A, Rs. 2,30,000/- for Bank B, Rs. 2,20,000/- for Bank C, and Rs. 2,10,000/- for Bank D. The chances of mistakes, thus, are not reduced much.

This is one problem which I always encounter while filing these forms. Given below is another problem which I have faced several times.

What if I open another FD in Bank A which will give me an interest of Rs. 10,000/- during the financial year after I submitted Form 121 to the bank? My estimated income for the year will still be below Rs. 4 Lakh and the bank should not impose TDS on my interest payments. However, as per rules, I should resubmit Form 121 to the bank with modified data otherwise the bank will start deducting IT on source not only on my future payments but also on interest already paid to me. What should I write in the revised form — How many forms have I submitted earlier? 3 or 4? There is no clarity from the IT Deptt. on this.

Due to these difficulties, it would have been better If they had deleted Column 11 altogether. And then there would have been no need to introduce Column 12 which was not there in Forms 15G/15H. In any case, they are asking the tax-payer to furnish the estimated total income for the year in Column 13. That should be sufficient.

In the proposal which I have submitted to the Income Tax Deptt., there is no need to furnish this information and even then they would be immediately able to find out the total income for which the taxpayer has filed Forms 121. See the post given below:

**PAPERLESS SYSTEM TO REPLACE FORM 121**