CA K Sanjay BhargavChartered Accountant
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Tax audit season: the dates, and what to have ready

CA K Sanjay Bhargav, Chartered Accountant, Bengaluru

Membership No. 250054 · DISA (ICAI)

Published · Last updated

Does tax audit apply to you this year?

The Section 44AB test on your own figures. It also decides your filing date — audit liability, not the form number, is what puts you on 31 October rather than 31 August.

Business or profession?

Short answer: for FY 2025-26 (AY 2026-27), the tax audit report is due by 30 September 2026 and the return for audit cases by 31 October 2026. Late filing of the audit report attracts a penalty under Section 271B of 0.5% of turnover, capped at ₹1,50,000 — subject to relief for reasonable cause.

With the salaried filing season closed, this is the window that matters for businesses and professionals.

The dates for this season

ObligationDue date
Return — ITR-1 / ITR-2 filers31 July 2026
Return — ITR-3 / ITR-4 filers not liable to audit31 August 2026
Tax audit report — Form 3CA or 3CB with 3CD30 September 2026
Return of income, audit cases31 October 2026
Transfer pricing report, where applicable31 October 2026
Return where transfer pricing applies30 November 2026
Belated return under Section 139(4)31 December 2026
Revised return under Section 139(5)31 March 2027 — fee under new Section 234-I for revising late in the window: ₹1,000 if income ≤ ₹5 lakh, else ₹5,000

The 31 August date is statutory and permanent, and it applies to this year.

The Finance Act 2026 substituted Explanation 2 to Section 139(1) of the Income-tax Act, 1961 with effect from 1 March 2026, replacing the single 31 July date with a four-tier table:

PersonDue date
Where transfer pricing under Section 92E applies30 November
Company, or assessee whose accounts require audit, or partner of such a firm31 October
Business or profession income, accounts not requiring audit31 August
Any other assessee31 July

Because the amendment took effect on 1 March 2026, it governs AY 2026-27 — the year being filed now. It is a statutory change, not a departmental extension, so it recurs every year rather than lapsing.

The same structure has been carried into the new code: the Finance Act 2026 substituted an identical table in Section 263(1)(c) of the Income-tax Act, 2025 for tax year 2026-27 onwards, reading Section 172 in place of Section 92E. So the position is the same under both Acts, and will not change when the 2025 Act takes over.

What decides which row applies is audit liability under Section 44AB, not the form number. An ITR-3 filer liable to audit follows 31 October.

Extensions are sometimes granted by the Board close to a deadline. Planning around one is a poor strategy — the extension, if it comes, arrives too late to be useful to anyone who was relying on it.

Whether audit applies to you

The thresholds under Section 44AB:

  • Business — turnover exceeding ₹1 crore, extended to ₹10 crore where cash receipts and cash payments are each 5% or less of the total. Most businesses operating digitally satisfy that test comfortably.
  • Profession — gross receipts exceeding ₹50 lakh. This is a flat limit; the digital-receipts relaxation that raises the business threshold does not apply to it.
  • Presumptive opt-out — a taxpayer who used Section 44AD and then declares income below the presumptive rate, while exceeding the basic exemption limit, can be brought into audit. The presumptive taxation guide sets out that trap and the five-year lock-in that goes with it.

Applicability is decided on the numbers rather than assumed from last year — a business that was outside the threshold in the previous year can be inside it now. The audit and assurance page covers the wider position, including statutory and internal audit.

What late filing actually costs

Section 271B provides a penalty of 0.5% of total sales, turnover or gross receipts, capped at ₹1,50,000.

Two points are worth knowing:

It is not automatic. Section 273B allows the penalty to be dropped where there was reasonable cause. Serious illness, records seized in a search action, and delay attributable to a previous auditor have been accepted in practice. But reasonable cause must be pleaded and evidenced — it is not applied on its own.

File the report even if you are late. The audit report and the return are separate obligations. Getting the report on record limits exposure under 271B even where the return slips, and treating them as one deadline is a common and costly error.

Separately, a return filed after the due date loses the ability to carry forward business losses, which for a loss-making year is frequently a larger consequence than the penalty itself.

From tax year 2026-27 the consequence changes shape entirely. Under the Income-tax Act 2025, audit is Section 63, and failing to get accounts audited and furnish the report stops being a discretionary penalty and becomes a graded fee under Section 428(c)₹75,000 where the failure runs up to one month, and ₹1,50,000 thereafter. A parallel fee under Section 428(d) applies to the accountant's report under Section 172 (₹50,000, then ₹1,00,000).

That is a materially different regime. The 0.5%-of-turnover formula is gone, so a small business no longer benefits from the percentage cap being lower than the ceiling — a one-month slip is ₹75,000 regardless of turnover. And because it is a fee rather than a penalty, the Section 273B "reasonable cause" relief that applies to the 271B penalty does not obviously carry across. For AY 2026-27, though, the 1961 Act still governs and Section 271B is the correct provision.

The step that catches people out

After your auditor uploads the report, you must accept it from your own login on the e-filing portal. An uploaded report sitting unaccepted is not filed, and the deadline keeps running.

This is among the most common reasons a report completed well before the deadline is nonetheless treated as late. Check the acceptance status yourself rather than assuming that upload concluded the matter.

What to have ready

The audit stalls on the same items every year. Having these ready compresses the timeline materially:

Books and financials

  • Trial balance, profit and loss account and balance sheet for FY 2025-26
  • Ledgers, cash book and bank book
  • Last year's audited financials and tax audit report
  • Fixed asset register with additions, deletions and depreciation working

Third-party confirmations

  • Bank statements for the full year, all accounts, with reconciliations
  • Closing stock statement with the basis of valuation
  • Debtor and creditor balances, with confirmations where material
  • Loan statements and interest certificates

Tax records

  • GST returns for the year and reconciliation of GST turnover with books
  • TDS returns filed, challans, and Form 26AS
  • Advance tax and self-assessment tax challans
  • Details of any related-party transactions

Specific to Form 3CD clauses

  • Cash payments above the permitted limit, if any
  • Loans and deposits accepted or repaid otherwise than by banking channel
  • Payments to related parties
  • Amounts disallowable for TDS default
  • Employee contributions to provident and other welfare funds, with actual deposit dates

That last one deserves attention. Employee contributions deposited after the due date under the relevant labour law are disallowed, and the position has been settled against taxpayers. It is examined every year, and the deposit dates should be reconciled before the auditor raises them rather than after.

The reconciliation that decides how smoothly it goes

GST turnover against books. Differences are normal — GST turnover includes items that books treat differently, and the treatment of exports, credit notes and schemes creates genuine gaps. What matters is that each difference is explained and documented rather than discovered mid-audit.

If the two do not tie and no one can say why, the audit slows down and the difference becomes a question in every subsequent proceeding, because both figures sit in the department's own data.

The same set of financials usually has a second job. Where a facility is being renewed or applied for, the bank will want a CMA project report for a bank loan drawn from these figures — and a lender comparing your CMA against your filed turnover will notice any gap just as readily as an officer would.

Under the Income-tax Act 2025

Concept1961 Act2025 Act
Books of account44AA62
Tax audit44AB63
Presumptive taxation44AD, 44ADA, 44AE58 (consolidated)
Return filing139263

Audits for FY 2025-26 remain under the 1961 Act. Form and rule numbering is being revised for the new regime, so the applicable forms for a later year should be confirmed rather than carried over. The section mapping guide covers the wider renumbering.

For a trader the audit question turns on a turnover figure that is not the one the broker's statement puts in front of you, and is usually a small fraction of it — see the number that triggers an audit.


Due dates and thresholds are stated for AY 2026-27 and can be varied by the Board. Whether audit applies in a particular case depends on the figures and the nature of the activity, and should be confirmed against them.

Frequently asked questions

What are the due dates for FY 2025-26?

For assessment year 2026-27: 31 July 2026 for ITR-1 and ITR-2 filers; 31 August 2026 for filers of ITR-3 and ITR-4 who are not liable to audit; 30 September 2026 for the tax audit report; 31 October 2026 for the return where audit under Section 44AB applies; and 30 November 2026 where transfer pricing provisions apply. Belated returns run to 31 December 2026 and revised returns to 31 March 2027.

Is the 31 August date a one-time extension?

No. The Finance Act 2026 substituted Explanation 2 to Section 139(1) of the Income-tax Act, 1961 with effect from 1 March 2026, replacing the single 31 July date with a table: 30 November where transfer pricing under Section 92E applies, 31 October for companies and audit cases, 31 August for business or profession income not requiring audit, and 31 July for everyone else. Because it took effect on 1 March 2026 it governs AY 2026-27, and being statutory it recurs annually rather than lapsing. The same table has been carried into Section 263(1)(c) of the 2025 Act for tax year 2026-27 onwards. What decides which row applies is audit liability under Section 44AB, not the form number — an ITR-3 filer liable to audit still follows 31 October.

What is the penalty for not getting the audit done in time?

Under Section 271B the penalty is 0.5% of total sales, turnover or gross receipts, subject to a maximum of ₹1,50,000. It is not automatic — Section 273B provides relief where there was reasonable cause, and genuine reasons such as serious illness, records seized in a search, or a delay attributable to the previous auditor have been accepted. The relief has to be claimed and substantiated, not assumed.

Do I still have to file the audit report if my return is late?

Yes, and it should be filed regardless. The audit report and the return are separate obligations, and getting the report on record limits exposure under Section 271B even where the return itself slips. Treating the two as a single deadline is a common and expensive error.

My accounts are audited under the Companies Act. Do I need a separate tax audit?

They are different obligations under different statutes. A company's statutory audit under the Companies Act examines whether the financial statements give a true and fair view. A tax audit under Section 44AB reports the particulars the income-tax law requires. A company crossing the Section 44AB threshold needs both, and the tax audit report is furnished in Form 3CA where the accounts are already audited under another law.

Which form is my audit report filed in?

Form 3CA where the accounts are already required to be audited under another law, such as a company audited under the Companies Act; Form 3CB in other cases. In both instances the statement of particulars is in Form 3CD. Form and rule numbering is being revised as the Income-tax Act 2025 regime comes in, so the applicable form for a later year should be confirmed rather than assumed.

Does the report take effect once my auditor uploads it?

No. After the auditor uploads the report, you must accept it from your own login on the portal. An uploaded report left unaccepted is not filed, and the deadline continues to run. This is one of the more common reasons a report that was completed on time is treated as late.

Tax audit due this season?

Send your turnover figure, the nature of the business and last year's financials. Whether audit applies, under which clause, and what the timeline looks like is confirmed before anything begins.

Related service: Audit & Assurance