19 September 2025
Here is the ready reckoner checklist of major clauses to be mentioned in the Tax Audit Report (Form 3CD) for a Private Limited Company. Each clause refers to the key disclosure or reporting requirements that the tax auditor must examine and document.
Basic Assessee Information Name of the assessee.
Address of the assessee.
PAN/Aadhaar Number.
Status of the assessee (Individual/HUF/Firm/LLP/Company/Trust, etc.).
Previous year and Assessment year.
Clause under which tax audit is conducted (Section 44AB).
19 September 2025
Transfer Pricing & Other Clauses Details of primary adjustment to transfer price under Section 92CE(1).
Interest or similar expenditure exceeding ₹1 crore referred under Section 94B(1).
Amount received and forfeited taxable under Section 56(2)(ix).
Gifts/deemed gifts taxable under Section 56(2)(x).
Additional Checklist Points Provisions for gratuity and leave encashment, including actuarial valuation where limit exceeded.
Bifurcation of long-term liabilities and recognition of current liabilities.
Review of all creditors against expenses and ensure proper year-end provisions.
This checklist provides a comprehensive structure to ensure that all necessary clauses and disclosures as per the latest requirements for tax audit (Form 3CD) for private limited companies are covered in the audit report.
19 September 2025
Major Clause Updates for FY 2024-25 Clause 8a: Tax auditor must report whether the company has opted for the special tax regime under sections like 115BA/115BAA/115BAB/115BAC/115BAD/115BAE, reflecting the default new tax regime for FY 2024-25.
Clause 12: Now includes reporting of income assessable on a presumptive basis, expanded to cover Section 44BBC (special provision for broadcasting, telecasting, or sports event income).
Clause 19: Several deduction reporting sections have been omitted, including Section 32AC (investment in new plant/machinery), Section 32AD (investment in notified backward areas), Section 35AC (eligible projects), and Section 35CCB (agro-based research programs).
19 September 2025
Clause 21: Requires specific disclosure for expenses related to regulatory violations, settlements, penalties, etc. Such expenses are not tax-deductible and must be disclosed separately.
Clause 22: Disclosure requirements for payments to micro and small enterprises have been strengthened, especially regarding the interest on delayed payments which is not allowable as deduction if deadlines are missed.
Clause 26: Updates on amounts covered under Section 43B, ensuring compliance with statutory due dates for payments such as PF, ESI, GST, etc..
Clause 31: Major overhaul requiring more granular reporting of loans and deposits under Sections 269SS and 269T, including Nature, Amount, Code Type, and cheque/draft repayment details.
Clause 32: Reporting of brought forward loss or depreciation, with fields updated per schema changes.
New Clause 36B: Fields added to report specific amounts received, now mandatory in certain cases.
19 September 2025
Actionable Ready Reckoner Tips Use latest offline utility/schema for Form 3CA-3CD/3CB-3CD. Earlier file versions will be rejected by portal.
Ensure audit disclosure covers new clauses and omits redundant ones per the revised schema.
Review and follow the updated checklist and reporting format as per notification and schema v2.2 for error-free compliance.
These updates are mandatory for all tax audit reports for the financial year 2024-25; ensure audit procedures are updated to reflect these changes for private limited companies.
19 September 2025
Special Tax Regimes (Clause 8a): Tax auditors must report whether the company has opted for the special concessional tax regimes under sections 115BA, 115BAA, 115BAB, 115BAC, 115BAD, or 115BAE for FY 2024-25. This ensures proper documentation of tax choices aligned with new government policies.
Presumptive Income (Clause 12): The clause has been expanded to cover new sections such as 44BBC (business income of non-resident cruise ship operators). Income assessable on a presumptive basis under different sections, especially those newly added, must be specifically reported.
Deduction Details (Clause 19): Reporting formerly required for deductions under sections 32AC, 32AD, 35AC, and 35CCB has been removed, as these sections are now obsolete and not applicable for AY 2025–26.
19 September 2025
Regulatory Violations and Penalties (Clause 21): All expenses related to settlements, regulatory violations, and penalties must be reported. These are not tax-deductible and must be flagged distinctly, increasing transparency and ensuring such claims are not deducted from taxable income.
Payments to Micro and Small Enterprises (Clause 22): Disclosure requirements have been strengthened. Any interest paid on overdue payments is not allowable as a deduction, and auditors must specifically report instances where dues to micro/small enterprises exceed the timeline prescribed under Section 15 of the MSMED Act.
Digital Filing Utilities: The e-Filing portal now supports the new utility and schema for Forms 3CA-3CD/3CB-3CD, and prior versions will be rejected. Always use the current common offline utility when filing audit forms.