Indian transactions without a PAN — what works, what doesn't, 2026

"Can I do this without a PAN?" is among the most-asked NRI questions. The short answer is — sometimes, up to certain values, using Form 60 as a declaration substitute. The longer answer depends on what the transaction is, how much it is for, and whether the counterparty cares about downstream TDS or not. This page is the practical map: where PAN is hard-required, where Form 60 works, and what you can get done without either. All values and categories are based on Rule 114B of the Income Tax Rules as it stands in 2026.

What Form 60 does

Form 60 is a self-declaration filed by a person who does not hold a PAN when entering into a transaction that would otherwise require PAN under Rule 114B. It:

Is accepted in place of PAN for the specific transaction it is filed for.
Contains the declarant's name, address, date of birth, father's name, transaction amount, and a reason for not holding PAN.
Must be signed and dated at the time of the transaction.
Is retained by the counterparty for 7 years.
Does not exempt the declarant from any TDS, GST, stamp duty, or other statutory liability of the transaction itself.

The counterparty (bank, dealer, fund house, sub-registrar) collects Form 60 and routes the information to the Income Tax Department through its own reporting cycle.

Where PAN is required — Rule 114B categories

Under Rule 114B, PAN must be quoted for the following transactions. Where the person does not hold PAN, Form 60 is the acceptable substitute for all of these (subject to specific-section exceptions below):

#	Transaction	Threshold triggering PAN
1	Sale or purchase of motor vehicle (other than two-wheelers)	Any value
2	Opening an account (other than Basic Savings / Jan Dhan) with a bank or cooperative bank	Any value
3	Opening a demat account	Any value
4	Applying for a credit / debit card	Any value
5	Payment to hotel / restaurant in cash against a bill	> ₹50,000
6	Payment in cash for foreign travel / foreign currency	> ₹50,000 at one time
7	Payment to a mutual fund for units	> ₹50,000
8	Payment to a company / RBI for acquiring its debentures / bonds / shares	> ₹50,000
9	Cash deposit(s) with a bank / post office	> ₹50,000 in a day or aggregate > ₹10 lakh in FY
10	Purchase of bank drafts / pay orders / banker's cheques in cash	> ₹50,000 in a day
11	Fixed deposit with a bank, NBFC, post office	> ₹50,000 or aggregate > ₹5 lakh in FY
12	Payment for one or more prepaid instruments (wallets) in cash / DD / pay order / banker's cheque	> ₹50,000 in FY
13	Life insurance premium	> ₹50,000 in FY
14	Sale / purchase of securities (other than shares)	> ₹1 lakh per transaction
15	Sale / purchase of shares of an unlisted company	> ₹1 lakh per transaction
16	Sale / purchase of immovable property	≥ ₹10 lakh by consideration or stamp-value
17	Sale / purchase of any goods or services (other than above)	> ₹2 lakh per transaction
18	Opening a current / cash-credit account	Any value

Rule 114B is the operational list. In 2026 almost every bank counter, mutual-fund portal, and property registrar runs an automated check that blocks transactions without PAN or Form 60 at the data-entry stage.

Where PAN is hard-required — Form 60 will not work

Some transactions have their own statutes that require PAN separately from Rule 114B. Form 60 does not substitute:

NRE / NRO / FCNR account opening — banks require PAN for NRI / OCI KYC irrespective of Rule 114B.
Demat account for trading Indian securities — depositories require PAN.
Mutual fund KYC (new investors) — AMCs require PAN in KYC registration.
Applying for a Section 197 Lower-Deduction Certificate — the AO cannot process without PAN.
Filing an Indian tax return — ITR forms require PAN.
Claiming DTAA treaty rates on Indian-source withholding — PAN is one of the three mandatory documents (with TRC and Form 10F).
TDS certificate issuance (Form 16 / 16A / 16B / 27Q) — payers reference recipient's PAN.
Repatriating NRO funds abroad — Form 15CA / 15CB reference PAN.
Receiving salary from an Indian employer — Section 192 TDS runs against PAN.
Transmission of inherited shares / mutual funds — AMC / DP require heir's PAN.

In these areas, the question "can I do it with Form 60?" does not arise — you need PAN.

What an NRI can genuinely do without PAN or Form 60

Low-value and some non-financial activities run without either:

Tourist hotel stays paid by card or small cash (below ₹50,000 per bill).
Restaurant bills paid in cash under ₹50,000.
Domestic flights and trains — passport / OCI card works; PAN not collected.
Taxi, autos, local transport.
SIM card — passport + visa / OCI for foreigners and OCIs; no PAN required.
Small retail purchases — clothing, groceries, everyday goods under ₹2 lakh per transaction.
Small cash currency exchange at authorised money changers up to the ₹50,000 threshold.
Occasional gifts, donations below threshold.
Telephone / internet bill payments in your name via OCI/passport-based KYC (for prepaid services).
Tourist visa extension (at FRRO) — passport-based, not PAN.

For a short tourist visit, a passport, an OCI card (if held), and a foreign credit card cover most needs without ever touching PAN.

The Form 60 worked examples

Buying a car in India

A returning NRI visiting for a few weeks buys a car outright:

PAN required under Rule 114B item 1 (any value).
Form 60 acceptable if the buyer does not hold PAN.
Dealer files Form 60 with the RTA for registration.
No TDS at purchase (GST is charged on the invoice; Form 60 does not affect GST).

Paying a hotel bill of ₹1.5 lakh in cash

PAN required under Rule 114B item 5 (cash

₹50,000).
Form 60 acceptable at the hotel's counter.
Most hotels prefer card / UPI — paying the ₹1.5 lakh on a card avoids Form 60 entirely.

Buying a motor scooter (two-wheeler)

PAN not required — two-wheelers are exempt from Rule 114B item 1.
No Form 60 either.
Dealer registers the two-wheeler against passport / OCI / Indian ID proof.

Depositing ₹75,000 cash into an Indian account

PAN required under Rule 114B item 9 (cash deposit > ₹50,000).
Form 60 acceptable at the bank.
The bank itself has KYC-linked PAN records for NRE / NRO / resident accounts — Form 60 is the pre- account-opening friction, not a single deposit issue.

Buying mutual fund units of ₹45,000

PAN not required under Rule 114B (below the ₹50,000 threshold).
But — PAN is required under SEBI KYC for new investors. AMCs block investments without PAN regardless of amount.
Effectively, the threshold test in Rule 114B never triggers because the upstream KYC already blocks.

Section 206AA — where "no PAN" becomes genuinely expensive

Rule 114B and Form 60 govern the transaction-level reporting side. A parallel rule — Section 206AA of the Income Tax Act — governs the TDS rate when the payer does not have a valid PAN of the recipient.

Where no PAN is on file, TDS applies at the higher of:

The applicable section's rate.
20%.

And DTAA-lower rates are unavailable.

The effect on NRI-income streams:

Income	Rate with PAN	Rate without PAN
NRO interest	10% (Section 195 NRI)	20%
Dividend from Indian company	20% (section 195 NRI, treaty may lower)	20% minimum
Long-term capital gains on listed equity	12.5% (post-July 2024)	20%
Rent from Indian property (NRI landlord)	30% + surcharge + cess	30% + surcharge + cess (no change, but DTAA relief blocked)
Property sale consideration (NRI seller)	12.5% LTCG rate typical	20% floor
Professional fees paid to NRI	10% / treaty	20%

Form 60 does not substitute for PAN for Section 206AA purposes. So NRIs with Indian-source income cannot rely on Form 60 as a strategy — the TDS cost quickly exceeds the PAN application fee.

Foreign remittance under LRS — the TCS angle

An Indian resident remitting funds abroad under the Liberalised Remittance Scheme faces TCS (Tax Collected at Source) at rates that depend on purpose and amount:

General remittance — 20% TCS on amounts above ₹10 lakh in a financial year (post-October 2023 / 2024 rules).
Education / medical — lower or nil TCS at moderate thresholds.

TCS is reported against the remitter's PAN. A resident remitter without PAN cannot complete the LRS remittance in practice; banks require PAN on the outward-remittance form. This is not an NRI issue — NRIs remit under different routes (NRO-to-abroad, NRE freely) — but it affects returning NRIs who become residents and start using LRS.

Practical framework

For NRIs and OCIs deciding whether to apply for PAN:

Tourist-only activity — PAN not needed; passport and OCI card are enough; Form 60 on the rare high-value cash transaction.
Any NRI banking activity — PAN required; do not rely on Form 60.
Any Indian investment — PAN required; Form 60 does not help.
Property transaction above ₹10 lakh — PAN strongly recommended; Form 60 is a last-resort; Section 206AA costs dwarf PAN fees. See registering property without PAN.
Indian-source income of any kind — PAN saves money directly via Section 206AA and DTAA access.

The PAN application fee is ~₹107 Indian dispatch / ~₹1,017 foreign dispatch. The e-PAN issues in 3–7 days. No realistic scenario justifies the friction of a repeated Form 60 regime for anyone with ongoing Indian financial activity.

Common pitfalls

Filing Form 60 when you already have a PAN but cannot find it. The Form 60 declaration ("no PAN allotted") is factually wrong; duplicate PAN applications after a Form 60 have drawn Section 272B penalty. Recover the existing PAN first. See recover a lost PAN.
Assuming Form 60 avoids TDS. It does not. Section 206AA 20% floor applies on the income.
Using Form 60 at a sub-registrar for property. Often refused; downstream TDS chain breaks.
Assuming small-value exemption covers a stream of transactions. Aggregate thresholds apply — ₹10 lakh cash deposits across the year, ₹5 lakh FD aggregate, ₹50,000 MF purchase aggregate — crossing any of these triggers PAN quoting.
Mixing Rule 114B with FATCA / CRS KYC. The two are different regimes. NRIs and OCIs need to file a FATCA / CRS self-declaration with Indian banks regardless of PAN / Form 60.
Paying cash at the ₹50,000 edge. Below ₹50,000 no PAN needed; above, PAN or Form 60. Split payments across days usually count as "aggregate in a day" for cash-deposit purposes; do not assume two ₹40,000 deposits are safer than one ₹80,000.
Using an old Form 60 template. The form has been revised; download the current format from the Protean / UTIITSL / Income Tax portal.

Checklist — planning your Indian transactions with or without PAN

List the activities for your Indian trip / period.
Identify each against Rule 114B — PAN / Form 60 required, or not.
Flag any Indian-source income — PAN is effectively mandatory to avoid Section 206AA.
If you already have PAN, verify operative status at verify your PAN.
If PAN would be needed more than once, apply for one — the process is quicker and cheaper than repeating Form 60.
For single-transaction no-PAN needs, download the current Form 60, fill accurately, and keep a copy.
Pay card / UPI / net-banking where possible to avoid the cash thresholds that trigger PAN.
For larger property / investment / banking moves, get PAN in hand before the transaction date.

Summary

Form 60 substitutes for PAN under Rule 114B — useful for occasional transactions by persons genuinely not required to hold PAN.
Hard-required PAN applies to bank account opening, demat, mutual-fund KYC, property registration paperwork beyond the sub-registrar, and all TDS / DTAA / Indian tax-return activity.
Low-value and non-financial tourist activity — passport and OCI card are enough; PAN / Form 60 not needed.
Rule 114B thresholds — ₹50,000 (cash, hotel, travel, insurance, MF, deposits), ₹1 lakh (securities), ₹2 lakh (general goods), ₹10 lakh (property), or any value for cars, bank accounts, demat, credit cards.
Section 206AA — without PAN, Indian-source income flows are taxed at a 20% floor and DTAA relief is blocked. Form 60 does not cure this.
Applying for PAN is cheap and fast — ~₹107 / ~₹1,017 with an e-PAN in 3–7 days; worth getting the moment any pattern of Indian financial activity appears.

For the PAN application itself, see PAN card — how to apply. For the NRI-specific PAN angle, see PAN for NRIs. For property- specific details, see registering property without PAN. For verifying PAN status, see verify your PAN. For common PAN misconceptions, see PAN card myths.