Form 3CD AY 2026-27 — Changes, Checklist and Transition to Form 26

TL;DR

For AY 2026-27 (FY 2025-26), file the old Form 3CA/3CB/3CD as usual. Due date: 30 September 2026. Do NOT use Form 26 for this year — it is not applicable yet. Do NOT reference Section 393 or other Income Tax Act 2025 section numbers in TDS clauses for FY 2025-26 filings — use the old section numbers (194C, 194J, etc.). Form 26 under the new IT Act 2025 takes over from Tax Year 2026-27 (FY 2026-27) onwards.

What Is Form 3CD and Who Needs It for AY 2026-27?

Form 3CD is the statement of particulars accompanying the tax audit report under Section 44AB of the Income Tax Act 1961, governed by Rule 6G of the Income Tax Rules 1962. It contains 44 clauses covering everything from method of accounting and turnover to TDS compliance, loans and advances, payments to related parties and quantitative details.

For AY 2026-27 (FY 2025-26), the old forms remain in force. This is the last assessment year for which 3CA, 3CB and 3CD are valid. The due date for filing the tax audit report for AY 2026-27 is 30 September 2026.

Who must file for AY 2026-27:

Business assessees with total turnover exceeding ₹1 crore (₹10 crore if 95%+ digital transactions)
Professionals with gross receipts exceeding ₹50 lakh
Presumptive assessees under Section 44AD/44ADA/44AE declaring income below the threshold
Assessees required to get accounts audited under any other provision of the Act

Form 3CD AY 2026-27 — Key Clause Checklist

The following table covers the clauses most likely to require careful attention for FY 2025-26 filings, along with the most common errors seen in practice:

Clause	What to Report	Common Error to Avoid
Clause 4	Whether assessee is liable for audit under any other law — if yes, give details	Omitting Companies Act or cooperative society audit when applicable, causing mismatch with Form 3CA
Clause 10	Method of accounting — mercantile or cash. Any change in method from previous year	Reporting change in method without quantifying the financial effect, which is mandatory
Clause 13	Method of stock valuation and deviation, if any, from the method used in the preceding year	Leaving the deviation field blank when the assessee has shifted from cost to NRV on slow-moving inventory
Clause 19	Amounts debited to P&L that are inadmissible under Sections 30 to 37 — i.e., personal expenses, capital expenditure claimed as revenue, etc.	Referencing Section 393 (IT Act 2025 equivalent) instead of the correct old Section 37(1) for FY 2025-26 filings
Clause 26	Amounts deemed to be income under Sections 41 and 176 — remission of trading liabilities, recovery of bad debts previously allowed, etc.	Missing deemed income where a liability was written back in the current year after earlier deduction
Clause 34	TDS/TCS compliance — payments subject to TDS, whether deducted, whether deposited on time, shortfall amounts	Using IT Act 2025 section numbers (e.g., Section 393) instead of the correct old section numbers (194C, 194J, 194H, etc.) for FY 2025-26
Clause 36	Particulars of each loan or deposit accepted or repaid — name, address, PAN, amount, whether by account payee cheque/NEFT	Omitting cash repayments above ₹20,000 that technically require reporting even if the original acceptance was compliant
Clause 44	Break-up of total expenditure of entities registered or not registered under GST — distinguishing exempt supply purchases, taxable purchases from unregistered dealers, etc.	Treating all purchases from composition dealers as taxable supplies instead of correctly categorising them

Critical Warning — TDS Section References for FY 2025-26

Do NOT use IT Act 2025 section numbers in AY 2026-27 filings

The Income Tax Act 2025 came into force on 1 April 2026. Its section numbering is completely different from the old Act. For example, what was Section 194C (TDS on contractor payments) is now Section 393 in the new Act. For FY 2025-26 (AY 2026-27), the old Act governs the transactions — you must use old section numbers in Clause 34 and elsewhere. Filing Form 3CD for AY 2026-27 with references to Section 393 or other IT Act 2025 numbers is factually incorrect and will not match the applicable law for that year.

The old Act and its section numbers remain in force for all transactions that occurred during FY 2025-26 — the date the new Act came into force (1 April 2026) is after the end of FY 2025-26. References in Clause 34 (TDS), Clause 19 (disallowances under Sections 30–37), Clause 26 (deemed income) and all other clauses must therefore use the Income Tax Act 1961 section numbering.

AY 2026-27 (Form 3CD) vs Tax Year 2026-27 (Form 26) — Side by Side

Parameter	AY 2026-27 / FY 2025-26	Tax Year 2026-27 / FY 2026-27
Form	3CA / 3CB + 3CD	Form 26 (unified)
Governing law	IT Act 1961, Section 44AB	IT Act 2025, Section 63
Number of clauses	44	53
Revision mechanism	No formal provision	Rule 47(3) — formal revision allowed
Due date	30 September 2026	30 September 2027

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Assessee Name: [ASSESSEE_NAME]

PAN: [ASSESSEE_PAN]

GSTIN: [ASSESSEE_GSTIN]

Financial Year: [FINANCIAL_YEAR]

Total Sales (Clause 15): ₹[TOTAL_SALES]

Total Purchases (Clause 15): ₹[TOTAL_PURCHASES]

Gross Profit: ₹[GROSS_PROFIT]

TDS Deducted and Deposited (Clause 34): ₹[TDS_DEPOSITED]

Date of Balance Sheet: [DATE_OF_BS]

Auditor UDIN: [AUDITOR_UDIN]

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Frequently Asked Questions

Can I use Form 26 for AY 2026-27 instead of Form 3CD?

No. Form 26 is prescribed under the Income Tax Act 2025 and is applicable only from Tax Year 2026-27 (FY 2026-27) onwards. For AY 2026-27 covering FY 2025-26, the portal only accepts the old Form 3CA/3CB/3CD. Using Form 26 for AY 2026-27 is not an option on the portal — you must file the old forms.

Are there any changes to Form 3CD itself for AY 2026-27 compared to AY 2025-26?

No structural changes have been notified for AY 2026-27. The form continues to have 44 clauses under the same Rule 6G framework. The key practical change for practitioners is ensuring that all section references — TDS sections in Clause 34, disallowance sections in Clause 19, deemed income sections in Clause 26 — use the Income Tax Act 1961 numbers, not the new IT Act 2025 numbers.

What happens to Form 3CD after AY 2026-27?

AY 2026-27 is the final assessment year for which Form 3CD is valid. From Tax Year 2026-27 (FY 2026-27) onwards, the Income Tax Act 2025 governs all tax audit requirements, and Form 26 is the only prescribed form. The old Form 3CD will no longer be accepted on the portal for any year after AY 2026-27.

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