Form 138 FVU file: filing the Q2 salary TDS return that replaced Form 24Q
Form 138 replaced Form 24Q for salary TDS from tax year 2026-27. How to prepare the Form 138 FVU file for Q2, due 31 October 2026, and the checks to run first.
Last checked 6 min read
The Q2 salary TDS return for 2026-27 is due on 31 October, and for most payroll teams it is only the second time they are filing it as Form 138 with a Form 138 FVU file. The first time, in July, many companies filed with outside help or by hand. This quarter is a good moment to set it up properly.
Here is what changed, what the file has to pass, and the checks that save a rejected return.
24Q replaced by Form 138: what moved where
The Income-tax Act, 2025 and the Income-tax Rules, 2026 apply from 1 April 2026, which is tax year 2026-27. Salary TDS moved from section 192 to section 392, and the forms were renumbered with it.
| Old form (to 2025-26) | New form (from 2026-27) |
|---|---|
| Form 24Q, quarterly salary TDS statement | Form 138 |
| Form 16, salary TDS certificate | Form 130 |
| Form 12BA, statement of perquisites | Form 123 |
| Form 12BB, employee's declaration | Form 124 |
The switch follows the tax year, not the filing date. A correction for a 2025-26 quarter is still a 24Q correction. Salary paid from April 2026 goes on Form 138. And yes, that means Form 130 instead of Form 16 next June: the first Form 130 is due by 15 June 2027.
Form 138 due date for each quarter
- Q1 (April to June): 31 July 2026, already gone.
- Q2 (July to September): 31 October 2026.
- Q3 (October to December): 31 January 2027.
- Q4 (January to March): 31 May 2027.
TDS itself is still deposited by the 7th of the following month, and by 30 April for March. The quarterly statement only reports what you deducted and deposited. If the deposits are wrong, the statement cannot fix them.
What the Form 138 FVU file is
The statement is not a PDF or a spreadsheet you upload. It is a text file in a fixed layout published by Protean. The return preparation utility (RPU) builds it, and the file validation utility (FVU) checks it line by line before it can be filed. Protean released the FVU for tax year 2026-27 on 1 July 2026, and by the time of writing it had reached version 1.2.
The Q1 to Q3 file carries four kinds of lines: a file header, a batch header for the deductor, one line per challan, and one line per deductee under each challan. The FVU checks formats (TAN, PAN, dates, BSR codes), and it checks that the numbers add up across those lines.
Q4 is different, because it also carries Annexure II, the full-year salary details of each employee. At the start of October Protean had not yet published the Q4 FVU for Form 138; it was listed as coming soon. Plan for Q4 now, but do not build a Q4 workflow on guesses.
Six checks to run before you generate the file
Most FVU errors come from the same few places. Run these first.
1. Every month's TDS sits on a challan. For July, August and September, the TDS deducted for each employee should be linked to a challan, and the total deducted should equal the total deposited.
2. Challan details match the bank. BSR code, challan serial number, date of deposit and amount, exactly as the bank stamped them. A single transposed digit fails the file.
3. Dates fall inside the quarter. Deduction dates for Q2 must be between 1 July and 30 September.
4. PANs are valid and operative. A PAN that is not linked to Aadhaar is inoperative, and the law treats it as no PAN at all. That changes the TDS, not just the file.
Take Sana, who joined a Gurugram firm in July on a taxable salary of ₹15,00,000 a year under the new regime. Her normal tax works out to ₹1,09,200 including cess, roughly ₹9,100 a month. If her PAN is inoperative, TDS is the higher of the average rate and 20%, so ₹3,00,000 for the year, ₹25,000 a month. Whether cess goes on top of that 20% is not settled; the safer default is no cess, but ask your CA. CBDT's Circular 9/2025 gives relief if the PAN becomes operative within two months of the end of the month of payment, so chase the Aadhaar link early, not in March.
5. The deductor and responsible person details are current. Address, PIN, phone, and the name and designation of the person responsible. If the person who signed Q1 has left, update it.
6. You have the Q1 token number. The Q2 statement refers back to the regular statement filed for Q1. Keep its token, the provisional receipt number, somewhere payroll can find it.
Getting the Form 138 FVU file through
The flow itself is familiar to anyone who filed 24Q:
- Prepare the statement data from payroll for the quarter.
- Generate the text file in Protean's layout, or import into the RPU.
- Run it through the current FVU. Fix every error it lists, then run it again.
- File the validated statement through the channel your company uses today, and keep the acknowledgement and token number.
If your payroll tool produces the text file directly, step 3 is still yours. Vatsin Payroll builds the Q1 to Q3 file in Protean's published layout and runs FVU-style checks before download, but the FVU is the referee, so validate with it every quarter. Q4 stays on the RPU route until Protean publishes the new layout.
Things that look small and are not
- Perquisites. If the company paid an employee's tax on an ESOP or gave meals above the exempt limit, those flow into Form 123 and later into the Q4 Annexure II. We explain the ESOP case in when the employer pays the employee's tax, and the canteen limit in the ₹200 meal perquisite.
- Exemption columns. Annexure II has separate columns for things like retrenchment compensation and voluntary retirement payments. Putting them in "other exempt" may give the same taxable income but can still fail a column-level check.
- One person, one PAN. Duplicate employee records, common after a rehire, show up as two deductees. Merge them before the file is built.
None of this is glamorous work. But a clean Q2 means a clean Q4, and a clean Q4 means Form 130 goes out in June without a dozen employees asking why their tax credit does not match. Start the checks this week, not on the 30th.