/ Tax Audit Post-Filing · Updated 2026-10-22
Tax audit filed, November follow-ups to execute.
Tax audit (Section 44AB) for AY 2026-27 was due 31 October 2026 for most assessees + 30 November 2026 for Form 3CEB TP audit cases. Post-filing, several follow-up actions are critical: ITR coordination (ITR-3 / ITR-5 / ITR-6 due 31 October / 30 November / 31 December), 43B(h) Year 2 handling, Clause 44 reconciliation review, specified financial transaction documentation. Here's the November-December follow-up playbook.
DC
Written by CA Durgesh Chavda
Chartered Accountant (ICAI) · Founder, Bharat Quantum Prospera · US incorporation, India-US DTAA, FEMA ODI, NRI taxation, cross-border structuring · LinkedIn
/ Post-Filing Reconciliation
What to verify.
- Form 3CA/3CB signed + e-filed: tax auditor's audit report signed and e-filed on income tax portal.
- Form 3CD + 44 Clauses verification: specific Clause 20 (Section 40(a) / 40A payments), Clause 22 (43B / 43B(h) MSE), Clause 32 (specified financial transactions), Clause 34 (Chapter XVII-B TDS), Clause 44 (GST reconciliation).
- CA signature + membership verification: ICAI UDIN (Unique Document Identification Number) generated for the audit report.
- Supporting workpapers: in audit firm's file (preserved 8 years).
/ Clause 22 Section 43B(h) specific review
The year-2 critical clause.
- Clause 22 expanded (post Finance Act 2023): specific line items for Section 43B(h) MSE disallowance + amounts paid in subsequent FY (reversal from prior year).
- Common error: not identifying Micro + Small enterprise suppliers; treating all suppliers as outside 43B(h) scope. Udyam certificate collection becomes compliance signal.
- Reconciliation: 43B(h) disallowance in current year + 43B(h) reversal from prior year payment = net 43B(h) impact on current-year taxable income.
- Documentation: Udyam certificates for each MSE supplier + payment date tracking + 45-day calculation per invoice.
/ Clause 44 GST reconciliation
The GST-Income Tax interface.
- Clause 44 requires reconciliation of Income Tax turnover with GST turnover (as per GSTR-1 + GSTR-9).
- Common differences: credit notes / debit notes timing, year-end sales returns, GSTR-1 vs 3B gaps, exempt supplies not in Income Tax but in GST, specific adjustments like discounts.
- Narrative explanation for each unreconciled item.
- Feeds into GSTR-9 Reconciliation (31 December 2026) + GSTR-9C Part II / III.
/ Form 3CEB TP audit (30 November 2026)
The next deadline.
- Form 3CEB applicable for any Indian company with international transactions above INR 1 crore (effectively every foreign-subsidiary subsidiary of Indian group).
- Deadline: 30 November 2026 for AY 2026-27.
- Content: all international transactions listed with each AE + nature + value + arm's-length method + benchmarking.
- Underlying documentation (Section 92D): entity profile + industry analysis + functional analysis + economic analysis + benchmarking study. Not filed but produced on scrutiny.
- Master File (Form 3CEAA) for groups above INR 500 crore + CbCR (Form 3CEAD) for ultimate parent of groups above EUR 750M.
/ ITR filing coordination
The November-December window.
- ITR-5 / ITR-6 / ITR-3 (tax audit cases): due 31 October 2026 (standard) or 30 November 2026 if TP audit applicable.
- ITR must reflect Form 3CD disclosures (43B(h), Section 40(a), Chapter XVII-B TDS, specified financial transactions).
- Advance tax Q3 (15 December 2026) coordination.
- Belated return window: 31 December 2026.
- Updated return window (Section 139(8A)): up to 31 March 2027 for AY 2026-27, with additional tax.
/ Common November post-filing attention
What to check.
- Form 3CA/3CB status on portal: accepted / rejected / pending.
- UDIN verification against ICAI records.
- Form 3CD Clause 22 (43B(h)) + Clause 44 (GST reconciliation) + Clause 34 (TDS) coherence.
- Specified financial transaction disclosure (Clause 32) matching Form 61A reports.
- Pending Section 148A(b) notices from November-December 2026 reassessment season - urgent response.
- Advance tax Q3 (15 December) computation based on finalised audited financials.
- GSTR-9 FY 2024-25 preparation (due 31 December 2026).
- Last updated: 2026-10-22.
/ Ready when you are
Tax audit filed. November-December follow-ups now.
Form 3CEB TP (30 Nov) + ITR (31 Oct/30 Nov) + Advance Tax Q3 (15 Dec) + GSTR-9 (31 Dec). BQP integrated engagement + priority turnaround.
FAQ
Common questions, answered.
What follow-ups are critical after tax audit filing on 31 October?
Form 3CA/3CB status verification on portal, UDIN check against ICAI records, Form 3CD Clause-by-Clause coherence (especially 22, 32, 34, 44), coordination with ITR filing (30 November TP cases, 31 October standard), 43B(h) MSE reversal tracking, Clause 44 GST reconciliation feeding into GSTR-9 (December 2026), advance tax Q3 (15 December), Form 3CEB TP audit (30 November).
Is Form 3CEB TP audit also due on 31 October?
No - Form 3CEB has its own deadline: 30 November 2026 for AY 2026-27 (one month after standard tax audit). Mandatory for any Indian subsidiary / company with international transactions above INR 1 crore. Benchmarking study + comparability analysis underlying + Master File + CbCR for in-scope groups.
What's Clause 44 of Form 3CD?
Clause 44 requires reconciliation of Income Tax turnover with GST turnover (as per GSTR-1 + GSTR-9). Line-by-line explanation of differences: credit notes timing, exempt supplies, year-end adjustments, discounts. Feeds into GSTR-9 reconciliation (December 2026). Common area of discrepancy requiring narrative.
How does Section 43B(h) show up in Form 3CD?
Clause 22 (expanded post Finance Act 2023): specific line items for amounts disallowed under 43B(h) in current year (MSE payment beyond 45 days) + amounts paid in current year where disallowance was reversed from prior year. Documented with Udyam certificates + invoice-level 45-day calculation.
What happens if Form 3CA/3CB wasn't filed by 31 October?
ITR filing blocked - cannot e-file ITR without Form 3CA/3CB linked on portal. Late filing fee under Section 234F: INR 5,000 (reduced to INR 1,000 for small income). Section 271B penalty for late tax audit: 0.5% of turnover or INR 1,50,000 whichever less. Belated filing possible but with penalties.
Does BQP handle tax audit + ITR + TP audit integrated engagement?
Yes - integrated November-December engagement. Tax audit Form 3CA/3CB/3CD + ITR filing + Form 3CEB TP audit + Master File + CbCR + GSTR-9 preparation + advance tax Q3 + Section 148 response if any notice received. Priority turnaround through November-December 2026 deadline cluster. WhatsApp +91 78018 87130.
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