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Government Introduces Stricter Rules on Financial Transactions Without PAN

Effective April 1, 2026, the government has made it more difficult for individuals to carry out high-value purchases and financial transactions without a Permanent Account Number (PAN). The new Income Tax Rules, 2026, have made PAN compulsory for a wider range of transactions, replacing the earlier Form 60 with the more restricted Form 97.

Understanding Form 97

Form 97 is a prescribed declaration form under the Income-tax Rules, intended for use by specified individuals who do not possess a PAN. The form can be furnished by individuals (excluding companies and firms) who do not have a PAN but are entering into specified transactions. It is also applicable to certain foreign companies operating through an IFSC banking unit, provided they have no taxable income in India. Minors are not eligible to use Form 97 and must instead quote the PAN of their parent or guardian.

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Key Changes in Scope

The scope of Form 97 has been significantly narrowed compared to its predecessor, Form 60. While Form 60 allowed non-PAN holders to undertake a broad range of financial transactions, Form 97 restricts this flexibility to a limited set of transactions, including:

Transaction TypeLimit
Property transactionsPrescribed limits
Opening bank accountsExcluding basic savings accounts and time deposits
Time depositsBanks or post offices
Insurance-related account-based relationshipsBeyond thresholds
Payments to hotels or convention centresAbove specified limits
Purchase or sale of specified goods or servicesExceeding thresholds

Where PAN is Now Non-Negotiable

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Form No. 97 is permitted only for limited transactions under Rule 159(2). Consequently, for all other eligible transactions listed in Rule 159(1), PAN is mandatorily required, and Form 97 cannot be used as a substitute. This means that individuals without PAN will face direct barriers in accessing financial markets, making investments, or even executing routine high-value purchases.

Experts Weigh In

According to experts, the revised framework significantly narrows the flexibility earlier available to individuals without a PAN. This shift indicates a move towards wider PAN-based compliance, even though limited exceptions still remain. The government's policy direction is clear, with a focus on deeper financial traceability.

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