New PAN Forms from April 2026: What Every Indian NRI in UAE Must Know
If you are an Indian national or OCI holder living in the UAE, and you tried to apply for or correct a PAN card in April 2026 using the same form you used before — it was rejected. Form 49A and Form 49AA no longer exist. Under India’s Income-tax Rules, 2026, effective April 1, 2026, every PAN application now follows a new four-form structure. Applications submitted on old forms after that date are returned without processing.
This affects a significant population: roughly 3.5 million Indians live in the UAE, many holding inherited property in India, NRO/NRE bank accounts, and investment portfolios — all of which require a valid PAN.
The Four New Forms: Who Uses What
| Old Form | New Form | Who It Applies To |
|---|---|---|
| Form 49A | Form 93 | Indian citizens — including NRIs and RNORs who hold an Indian passport |
| Form 49AA | Form 95 | Individuals who are not citizens of India — OCI holders, PIOs, foreign nationals |
| (new) | Form 94 | Companies and entities incorporated in India |
| (new) | Form 96 | Entities incorporated outside India |
For most Indians in the UAE — those holding an Indian passport — the applicable form is Form 93.
Form 93: What NRIs with Indian Passports Need
Form 93 replaces Form 49A and applies to all Indian citizens, including those resident abroad. Under Rule 158 of the Income-tax Rules, 2026, any individual who is non-resident or RNOR must provide their passport number as a mandatory field. This is new — the old Form 49A did not require it.
[!NOTE] Under the Income-tax Rules, 2026: NRIs who have been outside India for 182 days or more in a financial year are exempt from the Aadhaar requirement on Form 93. You are not required to provide an Aadhaar number. An Indian passport, on its own, satisfies Proof of Identity (POI), Proof of Address (POA), and Date of Birth — three requirements in one document.
This Aadhaar exemption resolves a chronic problem: NRIs who attempted to link Aadhaar to PAN through outdated processes routinely failed because Aadhaar captures an Indian residential address, while NRI applications require evidence of overseas residence. The new rules formalize the exemption.
Accepted documents for Form 93 (NRI applying from UAE):
| Document | Satisfies |
|---|---|
| Indian passport (with UAE visa stamp) | POI + POA + Date of Birth |
| UAE bank statement (within 3 months) | POA (alternative) |
| Ejari (UAE tenancy registration) | POA (alternative) |
An Indian passport with a current UAE residence visa page is the single most efficient submission. Most applications proceed with passport only.
Form 95: OCI Holders and Non-Citizens
Form 95 replaces Form 49AA and is designated exclusively for individuals who are not Indian citizens — including OCI (Overseas Citizen of India) cardholders and PIOs holding non-Indian passports.
Accepted documents for Form 95 (OCI holder in UAE):
| Document | Satisfies |
|---|---|
| Foreign passport (with UAE visa) | POI + POA + Date of Birth |
| OCI card | POI (supporting) |
| UAE bank statement (within 3 months) | POA (alternative) |
| Emirates ID | POI (secondary — may require Indian Consulate attestation or apostille) |
[!TIP] Emirates ID alone is not accepted as the sole Proof of Identity on Form 95. It can strengthen an application but requires the foreign passport to be the primary document. Any non-passport, non-OCI document submitted for Form 95 may require attestation by the Indian Consulate General in Dubai or Abu Dhabi, or an apostille from the UAE Ministry of Foreign Affairs.
When PAN Is Mandatory: Rule 114B
Section 139A(5)(c) of the Income Tax Act mandates PAN quotation for transactions prescribed by the Central Board of Direct Taxes (CBDT). Rule 114B of the Income-tax Rules lists 18 such transactions. The ones most relevant to UAE-based NRIs:
| Transaction | PAN Threshold |
|---|---|
| Purchase or sale of immovable property | Above ₹10,00,000 (₹10 lakh) |
| Mutual fund or securities investment | Above ₹50,000 per transaction |
| Fixed deposit (time deposit) | Above ₹50,000, or ₹5,00,000 annually |
| Opening NRO/NRE or any bank account | All transactions (no threshold) |
| Life insurance premium payments | Above ₹50,000 annually |
| Foreign travel payments | Above ₹50,000 |
[!NOTE] A proposal in the 2026 draft rules would raise the immovable property PAN threshold from ₹10 lakh to ₹20 lakh. As of April 1, 2026, this draft has not been formally notified. The active legal threshold remains ₹10 lakh under Rule 114B of the Income-tax Rules, 1962. Do not rely on the higher threshold until an official notification is issued.
The Property Sale TDS Trap: Section 195
If you are selling property in India from the UAE, the TDS mechanism matters more than the tax rate itself.
Under Section 195 of the Income Tax Act, when a resident Indian buyer purchases property from an NRI seller, the buyer is legally required to deduct TDS on the full sale consideration — not on the capital gain. The default TDS rate under Section 195 for property transactions is applied at the rate applicable to capital gains, which can result in a higher withholding than the seller’s final tax liability.
Applicable capital gains rates for NRI sellers (FY 2025-26 onward):
| Holding Period | Tax Rate | Notes |
|---|---|---|
| Long-Term Capital Gains (LTCG) — held >24 months | 12.5% flat (+ surcharge + cess) | Indexation removed post-July 23, 2024 for new acquisitions |
| Short-Term Capital Gains (STCG) — held ≤24 months | Slab rates | Applied to applicable income bracket |
| Without a valid PAN | 20% flat | No exemption, no treaty benefit |
The consequence of an invalid or misregistered PAN is a 20% flat TDS deduction with no recourse for DTAA (Double Taxation Avoidance Agreement) benefit between India and the UAE. The NRI can recover excess TDS by filing an ITR, but this takes months.
To reduce TDS below the Section 195 default rate, the NRI seller can apply for a Lower Deduction Certificate under Section 197 (Form 13) through the Income Tax e-filing portal before the transaction. This can reduce withholding to near the actual capital gains tax rate.
Budget 2026 administrative update: From October 1, 2026, resident Indian buyers purchasing property from NRI sellers no longer need to obtain a TAN (Tax Deduction Account Number). TDS can be deposited using a standard PAN-based challan — a significant simplification of a historically complex process.
Three Edge Cases for UAE Residents
“My PAN is deactivated. Can I still sell property?”
Under CBDT directives, Aadhaar-PAN linking failures have led to deactivation notices for resident Indians. Under the 182-day NRI exemption, Aadhaar-PAN linking is not required — deactivation notices issued specifically for non-linking do not apply. However, verify your PAN status on the ITD e-filing portal before initiating any transaction. A deactivated PAN triggers the 20% flat TDS rate and blocks Form 26AS credit.
“My name on the PAN is different from my passport.”
All digital financial transactions — bank KYC, property registration, securities purchases — require an exact name match between PAN, passport, and bank records. Submit Form 93 for a correction immediately. The e-PAN (digital PDF) arrives within 48 hours and is legally accepted for all digital transactions while the physical card is in dispatch.
“My PAN shows an old Indian address. Is that a problem?”
For NRIs, the ITD does not require an overseas address on the PAN card itself. The PAN number is the operative identifier. However, your NRO/NRE bank account’s KYC records must reflect your current overseas address — the bank’s system cross-references PAN with FATCA/CRS declarations. If your bank KYC is outdated, update it with the bank directly; this does not require a PAN correction.
Checklist: Before Any Property Transaction or KYC Update
- Confirm PAN is active — check on the ITD e-filing portal PAN verification tool
- Confirm name on PAN matches passport exactly (no initials where full name applies)
- Confirm Date of Birth on PAN matches passport
- If any detail is wrong: file Form 93 (Indian citizen) or Form 95 (OCI) for correction immediately
- For property sale: apply for Form 13 (Section 197) Lower Deduction Certificate before transaction
- Confirm your NRO/NRE bank KYC reflects your current UAE address
- For any transaction above ₹10 lakh: PAN must be quoted — no exceptions under Rule 114B