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Direct Tax

Tax Audit Under ITA 2025: Section 162 Threshold, Form 3CD and Due Dates Guide

VS Vikas Sharma 📅 March 26, 2026 ⏱️ 4 min read 👁️ 0 views
Legal Reference
Section 162 (tax audit -- turnover threshold), Section 163 (audit report Form 3CA/3CB/3CD), Section 270 (complete scrutiny), Section 274 (defective return), ICAI standards, ITA 2025

1. What is a Tax Audit?

A tax audit under Section 162 of ITA 2025 is a mandatory annual examination of a business or professional accounts by a Chartered Accountant, resulting in the filing of a specified audit report with the Income Tax Department. Unlike a statutory audit under the Companies Act (which is broader), a tax audit specifically examines income, expenses, compliance with tax provisions, and accuracy of the accounts from an income tax perspective. The CA certifies compliance and flags specific items in Form 3CD -- a detailed questionnaire covering over 40 tax-relevant points.

2. Tax Audit Turnover Thresholds

CategoryThresholdCondition
Business (non-digital heavy)Rs 1 croreAggregate turnover exceeds Rs 1 crore
Business (95%+ digital transactions)Rs 10 croreBoth receipts and payments 95%+ through banking channels
Professionals (non-presumptive)Rs 50 lakhGross receipts exceed Rs 50 lakh
Business opting out of 44AD (declaring below threshold)Any turnoverOpted out and income below 6%/8%
Professionals opting out of 44ADA (declaring below 50%)Any receiptsOpted out and income below 50%

3. The Two Forms: 3CA/3CB and 3CD

Tax audit involves two separate forms:

  • Form 3CA: Used when the accounts are already audited under another law (e.g., Companies Act statutory audit). The CA confirms that the statutory audit was conducted and attaches the tax-specific observations.
  • Form 3CB: Used when the accounts are NOT required to be audited under any other law. The CA conducts an independent audit and certifies the accounts.
  • Form 3CD: Mandatory with both 3CA and 3CB -- a detailed statement of tax-specific information (43 clauses covering depreciation, loans, payments above limits, related-party transactions, disallowances, etc.)

4. Due Date for Tax Audit Report

The tax audit report (Form 3CA/3CB + Form 3CD) must be filed on the IT Portal by:

  • 30 September for all non-transfer-pricing cases
  • 31 October for transfer pricing cases (where the assessee also has international transactions requiring Form 3CEB)
  • The ITR must be filed after the audit report -- ITR due date for audit cases is 31 October (non-TP) or 30 November (TP)

5. Key Contents of Form 3CD

Form 3CD is a comprehensive questionnaire. Key clauses include:

  • Clause 13: Method of accounting (mercantile or cash)
  • Clause 17: Admission of any liability -- contingent liabilities
  • Clause 18: Depreciation details -- rate-wise assets and depreciation claimed
  • Clause 19: Amounts admissible under Sections 33AB, 33ABA, 35D, 35DDA
  • Clause 21: Payments to persons specified under Section 40A(2) (related party payments)
  • Clause 22: Cash payments above Rs 10,000 (Section 40A(3))
  • Clause 26: Section 43B items -- PF, ESI, interest, MSME payments
  • Clause 30B: TDS defaults (Section 40(a)(ia) disallowances)
  • Clause 34: TDS compliance details
  • Clause 36B: MSME payment details (Section 43B(h))

6. Who Conducts the Tax Audit?

Only Chartered Accountants in practice can conduct tax audits under Section 162. Key conditions:

  • The CA must be a member of ICAI in good standing with a Certificate of Practice
  • Independence: the CA should not be an employee of the assessee
  • One CA can audit up to 60 tax audit cases per year (ICAI limit)
  • Signing partner: if a CA firm does the audit, a specific signing partner certifies the report with their membership number

7. Penalty for Not Getting Tax Audit Done

Failure to get a tax audit done when required (or failure to furnish the audit report by the due date) attracts penalty under Section 438 of ITA 2025:

  • Penalty: lower of 0.5% of total sales/turnover/gross receipts OR Rs 1,50,000
  • No penalty if there is reasonable cause for failure (illness, natural disaster, technical issues beyond control)
  • Interest: no specific interest charge -- but the resulting ITR filing delay causes Section 419 interest on unpaid tax

8. Tax Audit vs Statutory Audit

Many taxpayers -- especially companies and large firms -- are required to get both:

FeatureStatutory Audit (Companies Act)Tax Audit (ITA 2025)
AuthorityCompanies Act 2013Income Tax Act 2025
Conducted byCA (registered auditor)CA in practice
PurposeTrue and fair view of financial statementsTax compliance verification
Report formAuditor report under Companies ActForm 3CA + Form 3CD
FilingMCA portal (ROC)IT Portal

9. E-Filing of Tax Audit Report

Tax audit reports are filed electronically on the IT Portal:

  • CA logs in with CA credentials (UDIN generation mandatory)
  • Assessee logs in and accepts the audit report submitted by CA
  • UDIN (Unique Document Identification Number) from ICAI portal is mandatory for each audit report -- prevents fake certifications
  • The audit report is linked to the assessee PAN and assessment year

10. Voluntary Tax Audit: When Below the Threshold

Taxpayers below the tax audit threshold can voluntarily get a tax audit done. Benefits:

  • Provides credibility to the accounts for potential AO scrutiny
  • Identifies Section 43B, 40A(3), and TDS default issues before they become notices
  • Banks and financial institutions may require audited financials for large loan applications
  • For businesses in transition (turnover approaching threshold): proactively getting audit done avoids issues

11. Why TaxClue

Tax audit requires careful preparation of Form 3CD data across all 43 clauses, coordination between CA and business teams, and timely portal submission before the deadline. TaxClue provides end-to-end tax audit support. Contact us under ITA 2025.

Disclaimer
This article is for general informational and educational purposes only. It does not constitute legal, financial, or professional tax advice. Readers are advised to consult a qualified Chartered Accountant or tax professional before making any decisions. TaxClue Consultech Pvt Ltd accepts no liability. All case studies and examples in this article are illustrative only and do not represent actual persons or transactions.

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❓ Frequently Asked Questions
When is a tax audit required under ITA 2025?
Tax audit under Section 162 of ITA 2025 is required for: businesses with turnover above Rs 1 crore (or Rs 10 crore if 95%+ transactions are digital); professionals with gross receipts above Rs 50 lakh; any taxpayer who opts out of Section 44AD or 44ADA and declares income below the prescribed threshold (6%/8% or 50% respectively), regardless of turnover. The audit report must be filed by 30 September of the assessment year.
What is Form 3CD?
Form 3CD is a detailed statement of tax-specific information filed as part of the tax audit report. It has over 40 clauses covering: depreciation details, related-party payments, cash payments above Rs 10,000, Section 43B items (PF, ESI, MSME, loan interest), TDS defaults, business losses and unabsorbed depreciation, capital gains details, and more. Both Form 3CA/3CB (CA certification) and Form 3CD must be filed on the IT Portal by 30 September.
What is the penalty for not filing a tax audit report?
Under Section 438 of ITA 2025, failure to get a tax audit done or failure to file the audit report by the due date attracts a penalty equal to the lower of 0.5% of total sales/turnover/gross receipts OR Rs 1,50,000. The penalty does not apply if there is reasonable cause for failure. Additionally, the delayed audit report causes a delayed ITR -- which attracts Section 419 interest on unpaid tax.
What is UDIN for tax audit reports?
UDIN (Unique Document Identification Number) is a unique number generated by the ICAI portal for each certificate, report, or document signed by a CA. For tax audit reports, the signing CA must generate a UDIN from the ICAI portal and link it to the Form 3CA/3CB filing on the IT Portal. UDIN prevents fake CA certifications and allows anyone to verify the authenticity of a CA-signed document. Without UDIN, the tax audit report is considered invalid.
Is a company statutory audit the same as a tax audit?
No. A statutory audit under the Companies Act 2013 ensures financial statements present a true and fair view -- it is an annual requirement for all companies. A tax audit under Section 162 of ITA 2025 specifically verifies tax compliance -- it is required only when turnover exceeds the threshold. For eligible companies, both audits are needed separately. The statutory auditor and tax auditor can be the same CA firm but the reports are filed on different portals (MCA for statutory, IT Portal for tax audit).

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Vikas Sharma VERIFIED EXPERT
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