Next dueIncome Tax
7 NOVTDS / TCS deposit · Deducted in Oct 2026in 7 days 21 NOVITR filing · Audit cases · AY 2026-27 · extended from 31 Octin 21 days 15 DECAdvance Tax · 3rd (75%) instalment · FY 2026-27in 45 days 31 DECBelated / revised ITR · AY 2026-27in 61 days 30 SEPTax Audit Report · Form 3CA/3CB · AY 2027-28in 334 days 11 NOVGSTR-1 · Outward supplies · Oct 2026in 11 days 15 NOVPF & ESI · Contributions · Oct 2026in 15 days 20 NOVGSTR-3B · Summary return · Oct 2026in 20 days
All due dates

Financial Statement Formats Under the ICAI Guidance Notes

Where no law prescribes them, the financial statement formats come from ICAI's Guidance Notes on Financial Statements of Non-Corporate Entities and of LLPs, which now apply in two...

Published
Updated
Reading time
6 min
Questions
6 answered
  • High Complexity
Topic
Income Tax
Published
September 8, 2026
Last updated
Sep 8, 2026
Reading time
6 min
0:00
Last updated: September 2026Verified against: Government sources
Which year this governs

From the ICAI Guidance Note on Tax Audit (Revised 2026), the concluding edition under the Income-tax Act, 1961. The format requirement is an ICAI accounting requirement and does not change with the Act; only the reporting location moves — from Para 3 of Form 3CA / Para 5 of Form 3CB to the corresponding observation paragraph of Form No. 26 under rule 47 of the Income-tax Rules, 2026.

Two situations, two sources of financial statement formats

AssesseeWhere the financial statement formats come from
Company, society, charitable trust and similarThe respective law governing the assessee prescribes the form in which financial statements are prepared and presented; those provisions must be complied with
Proprietorship, partnership, LLP and similarLaw prescribes no specific format. The financial statement formats come from ICAI's Guidance Note on Financial Statements of Non-Corporate Entities and Guidance Note on Financial Statements of Limited Liability Partnerships

Paragraph 10.1 also fixes responsibility: maintenance of books and records, and preparation of the financial statements, is the responsibility of the assessee — not of the tax auditor.

The phased applicability

The two Guidance Notes were effective for periods beginning on or after 1 April 2024 where no format was prescribed by law. The Council, at its 451st meeting held on 30 and 31 March 2026, then decided that they apply to non-corporate entities such as proprietorships and partnerships, and to LLPs, in a phased manner:

PhaseCriteriaApplicable from
Phase IEntities whose turnover exceeds Rs 5 crore (FY 2025-26)Accounting periods beginning on or after 1 April 2025
Phase IIAll entities (FY 2026-27)Accounting periods beginning on or after 1 April 2026
Phase I is already in force for the audits being signed now

Phase I bites on accounting periods beginning on or after 1 April 2025 — that is, the year under audit in the current cycle. A non-corporate entity with turnover above Rs 5 crore that has presented its accounts in its own long-standing format is already non-compliant, and paragraph 10.5 requires the auditor to say so. Phase II removes the turnover filter entirely the following year.

Which entities the Non-Corporate Guidance Note covers

Note 1 to paragraph 10.2 lists them:

  • (a) Sole proprietorship firms
  • (b) Hindu Undivided Family
  • (c) Partnership Firms — both registered and unregistered
  • (d) Association of Persons — partnership firms not covered above, Body of Individuals, and Resident Welfare Associations
  • (e) Society registered under any law for the time being in force
  • (f) Trust, private or public, registered under any law or unregistered
  • (g) Statutory Corporations, Autonomous bodies and Authorities
  • (h) Any form of organisation engaged fully or partially in any business or professional activities

Item (h) is a sweep-up: an entity type not named in (a) to (g) is still covered if it carries on business or professional activity.

Where the financial statement formats are published

Paragraph 10.3 points to ICAI's Accounting Standards Board site for the illustrative Excel financial statement formats for both Non-Corporate Entities and Limited Liability Partnerships, at asb.icai.org under checklist and format. The Guidance Note does not reproduce the formats in its own text, so the current file has to be downloaded rather than taken from the book.

What the tax auditor must do

  1. Check whether the financial statements prepared and presented by a non-corporate entity, where law prescribes no format, are prepared in the format prescribed by ICAI for the previous year 2025-26 and onwards (paragraph 10.4).
  2. Where the applicable financial statement formats are not followed, make an appropriate observation (paragraph 10.5).
  3. State that observation in Para 3 of Form No. 3CA or Para 5 of Form No. 3CB, as the case may be (paragraph 10.6).

Those two paragraphs — Para 3 of Form 3CA and Para 5 of Form 3CB — are the same places the Guidance Note directs the auditor to record disagreement with the assessee's Form 3CD particulars under paragraph 7.3(d), and the impact of a refusal to produce records under paragraph 13.2. They are the standard home for qualifications in a tax audit report.

Worked example

AssesseeTurnover FY 2025-26Format usedReporting consequence
Partnership firmRs 8.40 croreFirm's traditional trading and profit and loss accountPhase I applies. Observation required in Para 5 of Form 3CB
Partnership firmRs 2.10 croreFirm's traditional formatPhase I does not apply for the year beginning 1 April 2025; it does from 1 April 2026 under Phase II
LLPRs 6.90 croreICAI LLP Guidance Note formatCompliant; no observation
Private companyRs 40 croreSchedule III, Division IGoverned by the Companies Act, not by these Guidance Notes; report in Form 3CA

Audit checklist

  • Establish first whether any law prescribes the format for this assessee.
  • For non-corporate entities and LLPs, test Phase I turnover against Rs 5 crore for FY 2025-26.
  • Download the current illustrative financial statement formats from ICAI's Accounting Standards Board site.
  • Compare the presented statements line by line against the applicable financial statement formats.
  • Where the format is not followed, place the observation in Para 3 of Form 3CA or Para 5 of Form 3CB.
  • Record that preparation of the statements is the assessee's responsibility in the engagement letter.
  • Plan for Phase II to catch every remaining client from 1 April 2026.

Common mistakes

  • Treating the Guidance Note financial statement formats as optional for a Phase I entity.
  • Applying them to a company whose format is prescribed by the Companies Act.
  • Making the observation in the wrong paragraph of the report.
  • Testing the Rs 5 crore turnover against the wrong financial year.
  • Assuming the auditor is responsible for preparing the statements in the correct format.
Quick recapKey facts & short answers

Key Facts About Financial Statement Formats

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

Who prescribes the format of financial statements?

For companies, societies and charitable trusts, the law governing the assessee prescribes the form. Where no law prescribes a format — proprietorships, partnerships, LLPs — ICAI's Guidance Notes apply.

What is the phased applicability?

Phase I covers entities whose turnover exceeds Rs 5 crore in FY 2025-26, for accounting periods beginning on or after 1 April 2025. Phase II covers all entities in FY 2026-27, for accounting periods beginning on or after 1 April 2026.

Ask the question before you sign — it is always cheaper than asking it afterwards.

— TaxClue Compliance Desk

Financial Statement Formats: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

Related Services & Guides

Was this article helpful?
About the author
Vikas Sharma Tax & Compliance Expert at TaxClue

Experienced in company registration, GST, trademark, and compliance. Helping Indian businesses stay compliant.

Updated:

Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

People also ask

Questions, answered

Short, direct answers to the 6 questions readers ask most on this topic.

For companies, societies and charitable trusts, the law governing the assessee prescribes the form. Where no law prescribes a format — proprietorships, partnerships, LLPs — ICAI's Guidance Notes apply.

Phase I covers entities whose turnover exceeds Rs 5 crore in FY 2025-26, for accounting periods beginning on or after 1 April 2025. Phase II covers all entities in FY 2026-27, for accounting periods beginning on or after 1 April 2026.

The 451st meeting of the Council held on 30 and 31 March 2026.

Sole proprietorships, HUFs, registered and unregistered partnership firms, associations of persons including bodies of individuals and resident welfare associations, societies, private or public trusts registered or unregistered, statutory corporations, autonomous bodies and authorities, and any organisation engaged fully or partially in business or professional activities.

The auditor is required to make an appropriate observation, and should state the same in his observation or qualification in Para 3 of Form No. 3CA or Para 5 of Form No. 3CB.

The assessee. Responsibility for maintenance of books and records and for preparation of financial statements is that of the assessee.