Tax Audit Update;
I. Tax Audit Report Due on 30th September, Not 31st October - Delay Can Cost Rs 1.5 Lakh. The Two Separate Deadlines for AY 2026-27:
1. Tax Audit Report (Form 3CA / 3CB - 3CD) - Due Date: 30th September 2026
2. Income Tax Return for Audit Cases - Due Date: 31st October 2026
II. Who is Liable for Tax Audit Under Section 44AB:
1. Business: Turnover exceeds Rs 1 crore in FY 2025-26
2. Business with Higher Threshold: Limit rises to Rs 10 crore if cash receipts and cash payments each do not exceed 5% of total receipts and payments
3. Profession: Gross receipts exceed Rs 50 lakh
4. Presumptive Scheme Cases: Persons covered under Section 44AD, 44ADA, 44AE who do not comply with scheme conditions
III. Penalty for Missing Tax Audit Report:
As per Section 271B, failure to get accounts audited or furnish report on time attracts penalty of 0.5% of total sales / turnover / gross receipts or Rs 1,50,000 whichever is lower.
IV. ICAI Caps Tax Audits at 60 Per CA From FY 2026-27 - No Sharing of Limit Between Partners. From 1st April 2026, the limit of 60 tax audit assignments will be reckoned strictly on a financial year basis. This is as per the Chartered Accountants (Limit on Number of Tax Audits) Guidelines, 2025, notified on 25th July 2025 and effective from FY 2026-27.
1. Overall Ceiling Per Member: The limit of 60 is the aggregate ceiling for an individual member. It includes all audits signed as proprietor and / or as partner of a firm(s). An individual member cannot sign more than 60 tax audit reports in a financial year.
2. No Proxy Signing: A partner of a firm cannot sign any tax audit report on behalf of any other partner. The practice of using quota of junior partners by senior partners will be stopped.
3. Limit Cannot Be Shared: The limit per partner in a CA firm cannot be distributed or shared between partners. If a firm has 4 partners, the firm limit is 240, but no single partner can sign more than 60.
4. Applicable Forms: The ceiling applies only to specified sub-categories under GST and Tax Audit for UDIN generation - Form 3CA and Form 3CB under Section 44AB(a), 44AB(b) and Combined Form 3CB under Section 44AB.
5. Computation Basis: The limit is computed based on the date of signing of the Tax Audit Report, not the date of UDIN generation. The UDIN system will aggregate audits done in individual capacity and across firms.
V. What is Excluded From the 60 Limit:
1. Tax audits under Section 44AB(c), (d) and (e) - related to persons covered under presumptive schemes Section 44AE, 44ADA and 44AD.
2. Revised tax audit reports will not be counted as a separate assignment.
3. Head office and branch audits of the same assessee for the same assessment year will be treated as one assignment.
VI. Why This Change:
1. To ensure quality of tax audit and prevent overload
2. To curb concentration of work with few senior partners
3. To stop malpractices and forgery - ICAI stated UDIN gives full control
4. To promote equitable distribution of professional opportunities.
Source CA.(Dr.)Raj Chawla