By the third week of April every year, my phone starts ringing. Not for new joinings or appraisal queries — for one specific panic: “Form 24Q Q4 FY 2025-26 kab tak file karna hai?” This year the call has an extra layer. Half the HR managers I speak to in Delhi NCR and Bahadurgarh are also asking — “What is this Form 138 everyone is talking about, and do I need to file that for January-March too?” If you’re carrying the same knot in your stomach, sit down with a chai. We’ll fix this in the next ten minutes.
TL;DR — What you actually need to do
- Form 24Q Q4 for FY 2025-26 is due 31 May 2026 — and you must file it on the OLD form, not the new Form 138.
- Q4 carries Annexure II: the annual salary computation that TRACES uses to generate Form 16 Part B.
- From 1 April 2026, the Income-tax Act, 2025 kicks in. Salary paid on or after that date will be reported on Form 138 (replacing 24Q) and certified on Form 130 (replacing Form 16).
- Form 16 for FY 2025-26 must be issued to your employees by 15 June 2026.
What is Form 24Q (and why Q4 is different)
Form 24Q is the quarterly statement employers file with the Income Tax Department to report TDS deducted on salaries under Section 192 of the Income-tax Act, 1961. You file it four times a year — Q1, Q2, Q3, and Q4. Quarters one through three carry only Annexure I: challan details and deductee-wise TDS for the three months in that quarter.
Q4 is special. Along with Annexure I, you also file Annexure II — a per-employee annual salary statement covering the full financial year. It includes gross salary, exemptions claimed (HRA, LTA, leave encashment), Chapter VI-A deductions, the tax regime opted, taxable income, and total TDS deducted across all four quarters. TRACES uses Annexure II to generate Form 16 Part B. Get this wrong, and every employee’s ITR gets affected.
The deadlines you cannot miss
Here’s the calendar on a single page:
| Quarter | Period | Filing due date | Annexure II? |
|---|---|---|---|
| Q1 | Apr–Jun 2025 | 31 Jul 2025 | No |
| Q2 | Jul–Sep 2025 | 31 Oct 2025 | No |
| Q3 | Oct–Dec 2025 | 31 Jan 2026 | No |
| Q4 | Jan–Mar 2026 | 31 May 2026 | Yes |
| Form 16 issuance | FY 2025-26 | 15 June 2026 | — |
Late filing of 24Q attracts a fee of ₹200 per day under Section 234E until the return is filed (capped at the TDS amount), plus a possible penalty between ₹10,000 and ₹1,00,000 under Section 271H. Miss 31 May and you also can’t generate Form 16 from TRACES on time — which becomes your employees’ headache during ITR season.
What changes from 1 April 2026 (the Form 138 story)
The Income-tax Act, 2025 replaces the 1961 Act for tax years starting 1 April 2026. Section 192 has been renumbered to Section 392. The form numbers have changed too:
- Form 24Q → Form 138 (quarterly TDS statement on salary)
- Form 16 → Form 130 (annual TDS certificate for salary)
- Form 26Q → Form 137 (non-salary)
- Form 27Q → Form 139 (non-resident payments)
Here’s the part most HR managers are missing: the new forms apply to salary paid on or after 1 April 2026. Salary for January, February, and March 2026 — even though you’re filing the return in May 2026 — still goes on the old Form 24Q with old Section 192 codes. Your first Form 138 will be filed in July 2026 for Q1 of FY 2026-27 (April–June 2026 salaries). Don’t mix the two periods. April 2026 salary and March 2026 salary go on different returns.
Step-by-step: filing 24Q Q4 the right way
- Reconcile every TDS challan. Match BSR codes, challan serial numbers, dates, and amounts paid for January, February, and March 2026 against your bank statements. A ₹1 mismatch will throw a default notice.
- Validate every employee’s PAN. Use the bulk PAN verification utility on TRACES before you file. An invalid or inoperative PAN means TDS gets deducted at 20% under Section 206AA — and Annexure II will reject those rows.
- Compile Annexure II per employee. For everyone on payroll between April 2025 and March 2026 (including those who left mid-year), pull together: gross salary, Section 10 exemptions, standard deduction (₹75,000 under new regime, ₹50,000 under old), profession tax, Chapter VI-A deductions like 80C / 80D / 80CCD(1B) (only if the employee chose the old regime), declared regime, and total TDS for the year.
- Generate the .txt return file. Use NSDL’s RPU (Return Preparation Utility) or your HRMS payroll module’s 24Q export.
- Validate using FVU. Run the file through the latest File Validation Utility (currently FVU v8.7). Fix every error before upload — even small ones like missing pin codes will be flagged.
- Upload on TIN-NSDL or the income tax e-filing portal. Sign with DSC (mandatory for companies and audited entities) or EVC.
- Download Form 16 Part A and Part B from TRACES from around the second week of June, generate digital signatures, and issue to employees by 15 June 2026.
What HR managers get wrong on Q4
- Letting employees switch regime in March. Under Section 115BAC, the regime declared by the employee at the start of the year is what your TDS computation must reflect. If they want to change it, that happens at ITR filing — not in Annexure II.
- Double-counting joiners. Someone who joined you in November 2025 may also appear in their previous employer’s 24Q for April–October. Always collect Form 12B from new joiners; it tells you exactly what the previous employer reported.
- Skipping standard deduction for resigned employees. Even if an employee left in July 2025, they’re entitled to the full standard deduction for the year of payment.
- Wrong section code. Use 92A for government salaries, 92B for non-government, and 92C for pensioners. Mixing these triggers a TRACES notice within days.
- Forgetting professional tax. PT is a deduction from salary income under Section 16(iii). HR teams in Maharashtra, Karnataka, West Bengal, Tamil Nadu, and Telangana often deduct it monthly but forget to feed the annual figure into Annexure II.
- Ignoring NPS Tier-I employer contribution. Up to 14% of basic + DA is deductible under Section 80CCD(2) for new-regime employees too. Many HR teams treat it as taxable.
Why this is brutal in Excel — and easier in an HRMS
If you process payroll in Excel (and many SMEs in Bahadurgarh, Rohtak, Jhajjar, and across Delhi NCR still do), 24Q Q4 is a two-week ordeal: chasing investment proofs, recomputing tax, hunting down the right standard deduction for resigned staff, then mapping it all to RPU’s column structure.
With a payroll system that runs the year cleanly, the Annexure II file should generate with one click. Every salary head, regime declaration, exemption, and challan reference is already tagged month by month. EZHRM’s payroll module is built for this — Indian statutory rules baked in, regime selection captured per employee at year-start, and a one-click 24Q export that loads cleanly into FVU. When April 2026 salaries hit, the same engine will toggle to Form 138 — no migration project, no panic.
Frequently asked questions
1. What is the due date for Form 24Q Q4 FY 2025-26?
Form 24Q for the fourth quarter (January to March 2026) of FY 2025-26 must be filed by 31 May 2026. Late filing attracts a fee of ₹200 per day under Section 234E (capped at the TDS amount) and a penalty of ₹10,000 to ₹1,00,000 under Section 271H.
2. Has Form 24Q been replaced by Form 138 from April 2026?
Yes — but only for salary paid on or after 1 April 2026. For Q4 of FY 2025-26 (Jan–Mar 2026 salary), you still file the old Form 24Q. The first Form 138 filing is due 31 July 2026 for Q1 of FY 2026-27.
3. What is Annexure II in Form 24Q and when is it required?
Annexure II is the per-employee annual salary statement: gross salary, Section 10 exemptions, deductions, regime opted, taxable income, and total TDS deducted across the financial year. It is filed only with the Q4 return and forms the basis for Form 16 Part B issued through TRACES.
4. Do I need to file 24Q if I deducted no TDS in Q4?
If no TDS was deducted, you can file a NIL declaration on the e-filing portal instead of a regular 24Q. Most CAs recommend filing the NIL declaration so you stay clean with future compliance checks. Skipping entirely is risky if any employee crossed the basic exemption.
5. By when must I issue Form 16 to employees for FY 2025-26?
Form 16 for FY 2025-26 must be issued by 15 June 2026. You can download it from TRACES only after Q4 24Q is processed without defaults — which usually takes 7–10 working days from upload, so file by mid-May to be safe.
6. Can I file 24Q without an Aadhaar-linked PAN for an employee?
You can file the return, but TDS is deducted at 20% for inoperative PANs under Section 206AA, and the deductee row will be flagged. Always run a PAN status check on TRACES before filing — a five-minute step that saves a month of correction returns.
The bottom line
24Q Q4 isn’t just a compliance checkbox — it’s how your team’s annual tax record gets built. If you’re tired of stitching salary data across spreadsheets every May, take a look at how EZHRM handles Indian payroll, statutory deductions, and Form 16 generation in one flow, with the Form 138 transition already factored in. Future-you in May 2027 will thank you.