With the September 30 tax audit deadline for Assessment Year 2026-27 approaching and no extension notified by CBDT as of this writing, chartered accountants and taxpayers subject to audit under Section 44AB (now Section 63 of the Income Tax Act, 2025) need a clear, no-surprises checklist to close out filings on time.
1. Confirm Applicability Before Anything Else
Do not assume last year's applicability carries over. Recheck turnover/gross receipts against the current thresholds, factor in the cash-transaction relaxation for businesses with limited cash dealings, and separately verify presumptive-taxation opt-out cases under Sections 44AD/44ADA/44AE, since opting out or exceeding presumptive limits can trigger audit even when turnover alone would not.
2. Reconcile Books Before Touching Form 3CD
- Match books of account with GSTR-1, GSTR-3B and GSTR-9/9C for the year - mismatches here are one of the most common sources of scrutiny notices post-filing.
- Reconcile TDS/TCS credits in Form 26AS and AIS against books; unexplained differences delay sign-off.
- Verify fixed asset additions/deletions and depreciation schedules match the audited financials, not just the tax computation.
3. Common Form 3CD Clauses That Cause Last-Minute Delays
- Clause 26 (Section 43B disallowances) - check MSME payment timelines carefully; delayed payments to micro and small enterprises beyond the prescribed period are disallowed in the year of accrual, not the year of payment.
- Clause 21 (amounts inadmissible) - loans/advances covered under deemed dividend provisions, personal expenses routed through business accounts, and penalty/fine payments are frequently missed.
- Clause 44 (GST expenditure breakup) - requires granular vendor-wise classification; start this early, it is the most time-consuming clause to compile.
4. Don't Leave UDIN and E-Filing Sequencing to the Last Day
Form 3CA/3CB-3CD must be e-filed and accepted by the assessee before the ITR itself is filed - and UDIN must be generated and linked within the ICAI-prescribed window. A rushed UDIN generation on deadline day is a leading cause of last-minute audit report invalidation.
5. Penalty Exposure for Missing the Deadline
Failure to get accounts audited and furnish the report in time attracts a penalty under Section 271B (now recast under the Income Tax Act, 2025) of 0.5% of turnover/gross receipts, capped at Rs 1,50,000 - avoidable entirely with early document collection and a clause-by-clause review, not a one-day scramble.
Practical Takeaway
Most audit-deadline stress is a documentation-sequencing problem, not a technical one. Firms that build a clause-wise checklist into their workflow in July-August, rather than starting reconciliations in the last week of September, consistently avoid both penalty exposure and reporting errors.
CA Mehul Agrawal is a Partner at Agrawal Khandelwal & Associates LLP, Chartered Accountants in Nashik and Sillod, Maharashtra, specializing in tax audit, GST and international taxation. More at agrawalkhandelwal.com.
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