Tax Audit Due Date AY 2026-27: 21 October 2026 (Extended), 31 October With Transfer Pricing
The tax audit report (Form 3CA/3CB + Form 3CD) is due 30 September for companies without transfer pricing (21 October 2026 for AY 2026-27 under CBDT Circular No. 07/2026) and 31 October with transfer pricing; the ITR follows on 31 October (21 November 2026 for AY 2026-27) and 30 November. A late audit attracts penalty u/s 271B — 0.5% of turnover, up to ₹1.5 lakh; a return filed without the report is defective.
HRA Research Desk
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Updated 10 Oct 2026: For AY 2026-27, CBDT Circular No. 07/2026 (28 Sep 2026) extends the tax-audit report date to 21 October 2026 and the ITR due date for audited (non-transfer-pricing) assessees to 21 November 2026.
The tax audit report under s.44AB ITA 1961 — Form 3CA or 3CB with Form 3CD — is due 30 September for a company without transfer pricing (for AY 2026-27, extended to 21 October 2026 by CBDT Circular No. 07/2026 dated 28 Sep 2026), and 31 October where the company has international transactions requiring a s.92E report; the ITR follows on 31 October (AY 2026-27: 21 November 2026, same circular) and 30 November respectively. Filing the audit late attracts a s.271B penalty of 0.5% of turnover (up to ₹1,50,000), and filing the return without the audit report makes the return defective.
What the law actually requires
Section 44AB requires the tax audit report to be obtained by the specified date — clause (ii) of the Explanation to s.44AB — which is one month before the s.139(1) due date (for AY 2026-27, non-TP cases: 21 October 2026, CBDT Circular No. 07/2026). A company needs a tax audit under s.44AB only if it crosses the s.44AB turnover thresholds. Where it does, the operative dates are:
The report is filed electronically on the income-tax portal with the auditor's DSC; the ICAI UDIN on the report confirms the audit was genuinely performed. The sequence matters: the report must precede the return, and both must be in place before the respective deadlines.
Why the report comes first. The assessee must obtain the report before furnishing the return — the return cannot be filed as if the audit will "catch up later". ICAI guidance reinforces the internal order: the auditor should complete the audit, finalise Form 3CD, and then sign Form 3CA/3CB — never sign the covering form with a half-done statement of particulars.
Worked example: Orion Logistics vs Globe Corp
Orion Logistics Pvt Ltd (no transfer pricing), turnover ₹15 crore — above the ₹10 crore threshold, so the tax audit is mandatory. Its FY 2025-26 (AY 2026-27) calendar:
Globe Corp Pvt Ltd (international transactions with a non-resident associate) must additionally furnish Form 3CEB (transfer-pricing report under s.92E) by 31 October; its audit report is due 31 October and its ITR-6 by 30 November. Missing the report date as a non-TP company (30 September normally; 21 October 2026 for AY 2026-27 under CBDT Circular No. 07/2026 dated 28 Sep 2026) means the whole sequence slips — the report lands after the deadline and s.271B applies: 0.5% of ₹15 crore = ₹7.5 lakh, capped at ₹1,50,000.
Practical implications
- The s.271B penalty is capped, and relief needs reasonable cause. The penalty is 0.5% of turnover or ₹1,50,000, whichever is less, and can be dropped only if reasonable cause is shown (s.273B). Separately, a return filed without the audit report is defective under s.139(9).
- A missing report makes the return defective. Filing ITR-6 without the tax audit report invites a s.139(9) defective-return notice; the department asks you to file again, and the delay compounds with s.234A/234B interest on any tax due.
- The audit report and the ITR must reconcile. The turnover, tax payable and TDS/TCS figures in Form 3CD flow into ITR-6; a mismatch between the two is an automatic scrutiny flag in the portal.
- The auditor's DSC and UDIN are prerequisites. Without a Class 3 DSC and a valid UDIN, the report cannot be e-filed; a sole practitioner over-committed in September is a real reason audits slip.
- Start the audit before the busy season. September is the crush for every CA practice — a company that hands its books to the auditor in mid-September is queuing at the back of a long line. The audit that slips past the report due date is usually the one that started late, not the one that was hard.
Changed FY 2025-26: For AY 2026-27, the non-TP dates are extended to 21 October 2026 (audit report) and 21 November 2026 (ITR) by CBDT Circular No. 07/2026 dated 28 Sep 2026.
If the audit slips past the deadline
The penalty is not automatic: under s.273B no s.271B penalty is imposed if you prove reasonable cause for the failure, and under s.274 it can only be levied by an order after you have been given an opportunity of being heard. Beyond that, the options are limited:
- File the report as soon as possible. The s.271B penalty (0.5% of turnover, capped at ₹1,50,000) is a one-time amount, not a running charge, so filing later does not increase it; filing promptly and documenting the reason for the delay supports a reasonable-cause plea under s.273B.
- Get the audit report e-filed before the ITR, even if late. The auditor e-files the report separately on the income-tax portal. A return filed without the audit report is defective under s.139(9); a return filed late but complete is at least a valid return. Having the report on the portal first avoids the defective-return cycle.
- Revise under s.139(5) if the figures change. If the belatedly completed audit changes the income figure, a revised return under s.139(5) is the route while its time limit is open. An updated return under s.139(8A) can only add to income: it cannot be a return of a loss (save a narrow exception), decrease the tax liability, or create or increase a refund, and it is barred once assessment proceedings for that year are pending or completed.
- Do not read the cap as permission to be late. The ₹1,50,000 cap applies to the s.271B penalty only. Interest under s.234A (late return) and s.234B (advance-tax shortfall) is separate, cumulative and uncapped.
Step-by-step: what to do
- Confirm whether TP applies. If the company has international transactions with an associate (s.92E), the due dates move a month later — confirm with the CA in June, not September.
- Book the auditor early. Agree the fieldwork dates in June; hand over trial balance, bank statements, TDS registers, GST turnover and the loan/share schedules in July.
- Compile the Form 3CD schedules in advance — the 43B add-backs, 40A(3) cash payments, related-party notes, and the GST-ITR turnover reconciliation (Clause 44).
- Track the dates in a compliance calendar: 30 Sep (report, non-TP; 21 Oct 2026 for AY 2026-27) → 31 Oct (ITR, non-TP; 21 Nov 2026 for AY 2026-27) / 31 Oct (report, TP) → 30 Nov (ITR, TP). AY 2026-27 extensions: CBDT Circular No. 07/2026 dated 28 Sep 2026.
- Verify the report before filing: auditor's DSC, UDIN, Form 3CD complete, figures reconciling with ITR-6.
- File the report first, then the return. Keep the acknowledgement for both.
FAQ
What is the tax audit report due date for a company without transfer pricing?
30 September of the assessment year; for AY 2026-27, extended to 21 October 2026 (CBDT Circular No. 07/2026 dated 28 Sep 2026). The ITR (ITR-6) is due 31 October (21 November 2026 for AY 2026-27, same circular). With transfer pricing, the report is due 31 October and the ITR 30 November.
What if we file the audit report after its due date (30 September; 21 October 2026 for AY 2026-27) but before the ITR?
It is still late. The report must be obtained by the specified date (clause (ii) of the Explanation to s.44AB: one month before the s.139(1) due date), and the report's own deadline (30 September; 21 October 2026 for AY 2026-27 under CBDT Circular No. 07/2026 dated 28 Sep 2026) governs the report itself for non-TP companies. A late report attracts s.271B; a return filed without the report is defective under s.139(9).
What is the penalty for a late tax audit?
Under s.271B, 0.5% of turnover or gross receipts, or ₹1,50,000, whichever is less. There is no minimum amount.
Which forms make up the tax audit report?
Form 3CA (where accounts are audited under another law, e.g. the Companies Act) or Form 3CB (otherwise), along with Form 3CD (the statement of particulars). The auditor e-files them with a DSC and UDIN.
Does the auditor sign 3CD before 3CA?
Yes — ICAI guidance is to finalise the statement of particulars (Form 3CD) before signing the covering audit report (Form 3CA/3CB).
Can the 271B penalty be waived?
Yes, if you prove reasonable cause for the failure: s.273B bars a s.271B penalty in that case. The penalty is not automatic; it needs an order passed after you have been given an opportunity of being heard (s.274). Keep evidence of the cause and file the report as soon as possible.
Sources
- Income Tax Act 1961, s.44AB, s.92E (transfer-pricing report), s.139(1) (due dates), s.139(9) (defective returns), s.271B (penalty)
- Income Tax Rules 1962 — Rule 6G (Forms 3CA, 3CB, 3CD); Form 3CEB
- ICAI — guidance on tax audit procedure and UDIN
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See Also
Frequently asked questions
What is the tax audit report due date for a company without transfer pricing?
30 September of the assessment year; for AY 2026-27, extended to 21 October 2026 (CBDT Circular No. 07/2026 dated 28 Sep 2026). The ITR (ITR-6) is due 31 October (21 November 2026 for AY 2026-27, same circular). With transfer pricing, the report is due 31 October and the ITR 30 November.
What if we file the audit report after its due date (30 September; 21 October 2026 for AY 2026-27) but before the ITR?
It is still late. The report must be obtained by the specified date (clause (ii) of the Explanation to s.44AB: one month before the s.139(1) due date), and the report's own deadline (30 September; 21 October 2026 for AY 2026-27 under CBDT Circular No. 07/2026 dated 28 Sep 2026) governs the report itself for non-TP companies. A late report attracts s.271B; a return filed without the report is defective under s.139(9).
What is the penalty for a late tax audit?
Under s.271B, 0.5% of turnover or gross receipts, or ₹1,50,000, whichever is less. There is no minimum amount.
Which forms make up the tax audit report?
Form 3CA (where accounts are audited under another law, e.g. the Companies Act) or Form 3CB (otherwise), along with Form 3CD (the statement of particulars). The auditor e-files them with a DSC and UDIN.
Does the auditor sign 3CD before 3CA?
Yes — ICAI guidance is to finalise the statement of particulars (Form 3CD) before signing the covering audit report (Form 3CA/3CB).
Can the 271B penalty be waived?
Yes, if you prove reasonable cause for the failure: s.273B bars a s.271B penalty in that case. The penalty is not automatic; it needs an order passed after you have been given an opportunity of being heard (s.274). Keep evidence of the cause and file the report as soon as possible.
Next steps on tax audit under section 44AB
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