Rule 47 of Income explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Rule 47 of the Income-tax Rules, 2026 prescribes the audit report under section 63 of the Income-tax Act, 2025. Forms 3CA, 3CB and 3CD are gone: the report is now Part A or Part B of Form No. 26, and the particulars are Part C and Part D of the same form.
The change in one line
For twenty-plus years the tax audit deliverable was a pair — an audit report in Form 3CA or Form 3CB, with a statement of particulars in Form 3CD annexed to it. Rule 47 collapses that pair into a single Form No. 26 with four Parts.
| Under the 1962 Rules (rule 6G) | Under the 2026 Rules (rule 47) |
|---|---|
| Form 3CA — where accounts are audited under another law | Form No. 26, Part A |
| Form 3CB — in any other case | Form No. 26, Part B |
| Form 3CD — statement of particulars | Form No. 26, Part C and Part D |
What rule 47(1) actually says
The report of audit of accounts required to be furnished under section 63 shall be:
- clause (a) — in the case of a person who carries on business or profession and who is required by or under any law other than the Act to get his accounts audited, in Part A of Form No. 26;
- clause (b) — in the case of a person who carries on business or profession but is not a person referred to in clause (a), in Part B of Form No. 26.
The dividing line is therefore unchanged in principle. A company audited under the Companies Act, 2013, or a co-operative society audited under its governing State Act, falls in clause (a) and uses Part A. A partnership firm or proprietorship with no statutory audit obligation outside the income-tax law falls in clause (b) and uses Part B.
Rule 47(2) says the particulars required under section 63 "shall also be in Part C and D of Form No. 26". Part C and Part D are components of the same form, not a separate annexure. A filing that completes Part A or Part B but leaves Part C and Part D blank is incomplete on the face of the rule.
Rule 47(3) — the revised audit report
This sub-rule deserves separate treatment because it is the operative provision practitioners will actually use. In full:
"The report of audit furnished under this rule may be revised by the person by obtaining a revised report of audit from an accountant as defined in section 515(3)(b), duly signed and verified by such accountant, and shall furnish it before the end of the relevant financial year succeeding the tax year for which the report pertains, if there is payment by such person after furnishing of the report under sub-rules (1) and (2) which necessitates recalculation of the disallowance under section 35 or section 37."
Unpacked, revision is permitted where all of the following hold:
- a report has already been furnished under sub-rules (1) and (2);
- the person makes a payment after that report was furnished;
- that payment necessitates recalculation of the disallowance under section 35 or section 37;
- a revised report is obtained from an accountant as defined in section 515(3)(b), signed and verified by that accountant; and
- it is furnished before the end of the financial year succeeding the tax year to which the report pertains.
Why sections 35 and 37 specifically
Sections 35 and 37 of the Income-tax Act, 2025 are the disallowance provisions that turn on actual payment — the successors to the section 40(a) / section 43B family of the 1961 Act. Their defining feature is that the answer can change after the audit report is signed, because it depends on when money actually moves. A statutory due paid after the report but before the return deadline changes the correct figure. Rule 47(3) exists to let the report catch up with that payment.
The window, stated precisely
"Before the end of the relevant financial year succeeding the tax year for which the report pertains." For a report pertaining to tax year 2026-27, the revised report must be furnished on or before 31 March 2028.
Rule 47(3) is drafted narrowly. It permits revision where a subsequent payment changes a section 35 or section 37 disallowance. It is not a general licence to revise a tax audit report for a typographical slip, a change of opinion, or a re-audit. Where a report needs correcting for some other reason, the position must be worked out on general principles and disclosed — the rule does not supply an answer.
Worked example
Sunrise Textiles LLP is audited under section 63 for tax year 2026-27. As at the date the audit report is signed — say 15 September 2027 — an amount of Rs 6,40,000 of employer contribution and statutory dues remains unpaid, and the auditor accordingly reports a disallowance of Rs 6,40,000 under section 37 in Part C of Form No. 26.
On 20 November 2027 the LLP pays Rs 6,40,000. That payment changes the correct disallowance figure.
Rule 47(3) applies: the LLP may obtain a revised Form No. 26 from an accountant within the meaning of section 515(3)(b), signed and verified, recalculating the section 37 disallowance, and must furnish it on or before 31 March 2028.
If instead the LLP discovered on 20 November 2027 that a fixed-asset addition had been misclassified, rule 47(3) would not be the route — no post-report payment is involved and no section 35 or section 37 recalculation is triggered.
Rule 6G and rule 47 compared
| Point | Rule 6G (1962) | Rule 47 (2026) |
|---|---|---|
| Parent section | Section 44AB, Income-tax Act, 1961 | Section 63, Income-tax Act, 2025 |
| Report where audited under another law | Form 3CA | Form No. 26, Part A |
| Report in other cases | Form 3CB | Form No. 26, Part B |
| Statement of particulars | Form 3CD (annexure) | Form No. 26, Part C and Part D |
| Revision trigger | Payment affecting section 40 or 43B disallowance | Payment affecting section 35 or section 37 disallowance |
| Revision deadline | End of the relevant assessment year | End of the financial year succeeding the tax year |
| Who signs the revision | An accountant under the Explanation to section 288(2) | An accountant as defined in section 515(3)(b) |
Compliance checklist for the 2026-27 audit season
- Replace every reference to Form 3CA / 3CB / 3CD in engagement letters, checklists and management representation letters with Form No. 26 and the correct Part.
- Decide Part A versus Part B on the same test as before — is there an audit obligation under a law other than the Income-tax Act, 2025?
- Complete Part C and Part D in every case; they are not optional annexures.
- Confirm the signatory qualifies as an "accountant" under section 515(3)(b).
- Diarise the revision window — 31 March 2028 for tax year 2026-27.
- Track post-report payments that touch section 35 or section 37 through to the revision decision; this should be a standing item in the post-signing file.
Common mistakes
- Filing Part A when the only audit obligation is under the income-tax law. That is a Part B case.
- Leaving Part D blank. Rule 47(2) names Part C and Part D.
- Treating rule 47(3) as a general revision power. It is limited to post-report payments affecting section 35 or section 37.
- Missing the revision deadline. It is the end of the succeeding financial year, not the return filing due date.
- Quoting section 40(a) or 43B in the revised report. Those sections belong to the 1961 Act; for tax year 2026-27 the provisions are sections 35 and 37 of the 2025 Act.