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Form 26 tax audit report 2027 — Form 3CD clause mapper

FY 2025-26 (AY 2026-27) is the last audit on Forms 3CA/3CB and 3CD. From tax year 2026-27, signed in September 2027, the tax audit report is a single Form No. 26 under Section 63 of the Income-tax Act, 2025 — 53 clauses, every section renumbered, schedules that open only when you answer Yes. Pick the Form 3CD clause you know and see where it went, which sections it now cites and what the auditor has to do differently.

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Pick the Form 3CD clause you know

Form 3CD clause (Income-tax Rules, 1962)

New in Form No. 26 for tax year 2026-27 — nothing like it in Form 3CD

Clause 14(b) to (e)

Accounting software used; cloud storage with IP address and country; compliance with Rule 46(8); address of the backup server in India.

Clause 39

MAT or AMT credit — year-wise entitlement, set-off, utilisation in the year and balance carried forward.

Clause 42

Head office expenditure of a non-resident disallowable under Sec 60.

Clause 43

Remittances reported in Part D of Form No. 145 (the old Form 15CA), by nature, with chargeable and non-chargeable amounts.

Clause 44

Property receipts claimed as not includible under Sec 92(2)(m), with the reason.

Clause 47

Every acquisition or transfer of unquoted shares, with book value and fair market value.

Clause 48

Loans or advances paid by the assessee that fall within Sec 2(40)(e).

Audit report, paragraph 3

The effect on income, loss or book profit of any qualification, adverse remark, disclaimer or emphasis of matter in the statutory audit report that the particulars do not already reflect.

Audit report, paragraph 5

Each observation is tagged to a clause (9 to 53) and typed: test-check basis applying materiality, based on management representation, unable to verify, or others.

How far to trust this map

Firm. Form No. 26 under rule 47 replaces Forms 3CA, 3CB and 3CD; it is filed for audits under Section 63; it applies from tax year 2026-27; it has 53 clauses. The new clause numbers and the 2025-Act sections shown here are taken from the text of the form.

Our reading. Which old clause corresponds to which new one. The Department has published a full statement only for depreciation (old clause 18 is clause 36); the rest is matched by subject matter from the two forms.

Check on the utility. The Department describes the form as Part A (assessee), Part B (statement of particulars), Part C (report where accounts are audited under another law) and Part D (report where they are not). The printed text sets the two reports ahead of the particulars. Clause numbers are the same either way, but cite part letters from the e-filing utility, not from memory.

Why start now

The new report is built from this year’s books.

Form No. 26 is first signed in September 2027, but it reports on the year that began on 1 April 2026. Transaction counts for TDS statements, mode codes for every loan entry and month-wise asset additions are far cheaper to capture as the year runs than to rebuild afterwards. CORAA reads them from the ledger as they are posted.

Need a section that is not on a tax audit clause? Income Tax Act 2025 section mapper · form number converter · TDS section converter

What replaces Form 3CA, 3CB and 3CD from tax year 2026-27

Under the Income-tax Act, 1961 a tax audit under Section 44AB was reported on Form 3CA (where the accounts were already audited under another law) or Form 3CB (where they were not), each with the statement of particulars in Form 3CD, under Rule 6G. Under the Income-tax Act, 2025 the audit obligation is Section 63, and Rule 47 of the Income-tax Rules, 2026 prescribes a single Form No. 26 that holds both audit reports and the statement of particulars. It applies to tax years beginning on or after 1 April 2026, so the first Form No. 26 is signed for tax year 2026-27. Audits of FY 2025-26 (AY 2026-27) remain on Forms 3CA/3CB and 3CD.

The statement of particulars runs to 53 clauses. Items 1 to 8 identify the assessee; clauses 9 to 53 are grouped under eleven headings — general information, books of account and method of accounting, receipts and income, expenses, prior period items, losses, depreciation and deductions, international taxation, other key parameters, TDS and TCS, indirect taxation, and quantitative details. Almost every clause is a Yes/No question, and a detailed schedule is filled in only where the answer is Yes. Every section reference is to the 2025 Act: Section 14 for the old 14A, Section 35(b) for the old 40(a), Section 36(4) for the old 40A(3), Section 37(2) for the old 43B, Sections 185, 186 and 188 for the old 269SS, 269ST and 269T.

The audit report itself changes in two ways. The auditor must state the effect on income, loss or book profit of any qualification, adverse remark, disclaimer or emphasis of matter in the statutory audit report that is not already reflected in the particulars. And each observation on the particulars must be tagged to a clause and typed — test-check basis applying materiality, based on management representation, unable to verify, or others. The form is signed by an accountant as defined in Section 515(3)(b), with membership number, firm registration number and UDIN.

The due date follows the return. Form No. 26 is to be furnished by the specified date — one month before the due date for the return of income under Section 263(1). Where the return is due on 31 October, the report is due on 30 September; where the return is due on 30 November, the report is due on 31 October.

Worked example — re-pointing a disallowance working paper for tax year 2026-27

A firm’s tax audit file for a manufacturing company has, for years, carried one working paper for “clause 21” of Form 3CD. The same client is audited for tax year 2026-27 in September 2027.

Inputs

Clause 21(h) — exempt-income expenditure, Sec 14AForm 26 clause 26 — Sec 14

Clause 21(a) — capital, personal, penalty items, Sec 37Form 26 clauses 27(c) and 28 — Sec 34

Clause 21(b) — TDS default disallowance, Sec 40(a)(ia)Form 26 clause 51 — Sec 35(b)(i)

Clause 21(d) — cash payments, Sec 40A(3)Form 26 clause 30 — Sec 36(4)

Clause 26 — statutory dues, Sec 43BForm 26 clause 32 — Sec 37(2)(a) to (f)

Clause 22 — MSME, Sec 43B(h)Form 26 clause 33 — Sec 37(2)(g)

Output

One old clause becomesSix places in the new form

TDS disallowance now sits withTDS/TCS particulars, not expenses

Report to signForm No. 26 under Section 63

Due30 September 2027 where the return is due 31 October 2027

The substance of each disallowance is unchanged, but the file index is not. A working paper titled by old clause number will send a reviewer to the wrong place, and a bare “Section 37” in the narrative now means pay-to-claim items, not general business expenditure. Re-index by new clause and cite both Acts for the first year.

Common mistakes

Using Form No. 26 for the FY 2025-26 audit

The audit of FY 2025-26 (AY 2026-27) is under Section 44AB of the 1961 Act and is reported on Forms 3CA/3CB and 3CD, even though it is signed after 1 April 2026. Form No. 26 starts with tax year 2026-27.

Working from a draft-form comparison table

The draft form circulated in February 2026 had 55 clauses; the notified form has 53. Comparison tables published before the Rules were notified on 20 March 2026 can be off by a clause or two. Check the date of anything you rely on.

Carrying old section numbers into the new report

Every reference in Form No. 26 is to the 2025 Act. The traps are numbers that exist in both Acts with different meanings: Section 37 is now the pay-to-claim provision (old 43B), Section 35 is the list of non-deductible amounts (old 40), and Section 36 holds the related-party and cash-payment disallowances (old 40A).

Looking for the TDS disallowance among the expenses

The disallowance for non-deduction or late deposit of TDS is not in the expenses part. It is clause 51, under TDS/TCS — 30% for resident payments under Section 35(b)(i) and 100% for non-resident payments under Section 35(b)(ii).

Leaving the statement-level TDS counts to September

Clause 50 asks, for each TDS or TCS statement, how many transactions were reported and how many were not, and the amount not reported, after the latest correction statement. That is a reconciliation of the ledger to each quarterly statement — far easier done quarter by quarter.

Treating loans by journal entry as outside the loan clauses

Clause 45 reports acceptances, receipts, payments and repayments with a mode code. The codes cover journal entries, conversion of assets or liabilities and transfers, as well as cash and non-account-payee cheques.

Assuming a clause is gone because it has no counterpart

Some Form 3CD clauses — GAAR, country-by-country reporting, demands under other tax laws — have no matching clause in the Form No. 26 text. That is a reading of the form. Keep the working paper until the utility and the Department’s guidance confirm the disclosure is not required.

Frequently asked questions

Which form replaces Form 3CA, 3CB and 3CD for tax year 2026-27 (FY 2026-27)?+

Form No. 26, prescribed by Rule 47 of the Income-tax Rules, 2026 for the audit under Section 63 of the Income-tax Act, 2025. It combines the audit report (the old 3CA or 3CB) and the statement of particulars (the old 3CD) in one form.

Is Form 26 applicable for the FY 2025-26 (AY 2026-27) tax audit?+

No. Form No. 26 applies from tax year 2026-27 — tax years beginning on or after 1 April 2026. Tax audits for FY 2025-26 (AY 2026-27) and earlier years continue on Forms 3CA/3CB and 3CD under the 1961 Act.

What is the new section for tax audit in place of Section 44AB?+

Section 63 of the Income-tax Act, 2025. The thresholds carry over: business turnover above ₹1 crore, or ₹10 crore where cash receipts and cash payments are each within 5%; professional receipts above ₹50 lakh; and presumptive-income cases where a lower income is claimed.

How many clauses are there in the new Form 26 tax audit report (2027)?+

Fifty-three, against 44 numbered clauses in Form 3CD. Items 1 to 8 identify the assessee and clauses 9 to 53 carry the particulars under eleven headings, each with its own schedule.

What is the due date for the Form 26 tax audit report for tax year 2026-27?+

30 September 2027 for an ordinary audit case — the rule is one month before the due date of the return of income under Section 263(1). Where the return is due on 31 October the report is due on 30 September, and where it is due on 30 November the report is due on 31 October.

Where is the old clause 21(h) on Section 14A in Form No. 26?+

Clause 26, the first clause under particulars of expenses. It asks for the amount inadmissible in respect of expenditure relating to income that does not form part of total income, even if that income has not accrued or been received during the tax year. The section is now Section 14.

Where are Sections 269SS, 269ST and 269T reported?+

In clause 45 of Form No. 26, limbs (a) to (d). The sections are now Section 185 (acceptance of loans and deposits), Section 186 (receipts of ₹2 lakh or more) and Section 188 (repayment). Each entry carries a code for the mode of the transaction.

Where is Section 43B reported?+

In clause 32, citing Section 37(2)(a) to (f) of the 2025 Act. Delayed payments to micro and small enterprises — the old Section 43B(h) — are reported separately in clause 33 under Section 37(2)(g).

Does Form No. 26 still require the GST expenditure break-up of clause 44?+

A shorter version. Clause 52(b) asks for expenditure relating to registered entities, to unregistered entities, and to goods or services exempt from GST. The Department has said the total no longer needs to be reconciled with the individual entries of expenditure.

Is UDIN required on Form No. 26?+

Yes. The Department’s guidance states that UDIN must be generated by the signing accountant and quoted, along with the membership number and, for a firm, the firm registration number.

Authoritative sources

CBDT

Income-tax Rules, 2026 — Rule 47 and Form No. 26 — Audit report and statement of particulars required to be furnished under Section 63; notified with the Rules on 20 March 2026 and applicable from tax year 2026-27.

CBDT

Income Tax Department — FAQs and Guidance Note on Form No. 26 — Confirms that Form No. 26 corresponds to Forms 3CA, 3CB and 3CD under Rule 6G, the due date one month before the Section 263(1) date, the trigger-based schedules, the typed observations and the changes to the depreciation, remittance, TDS and quantitative clauses.

Parliament

Income-tax Act, 2025 — Section 63 — Tax audit obligation in place of Section 44AB of the 1961 Act, with the specified date defined as one month before the return due date under Section 263(1).

CBDT

Income-tax e-filing portal — forms under the Income-tax Rules, 2026 — The e-filing utility is the authority on the layout and part lettering of Form No. 26 as it will be filed.

Always confirm against the latest version of the source. Regulations evolve and amendments are common.

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Last reviewed: 2026-10-01 · For informational purposes only — not professional advice.