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Income-tax Act 202512 September 20269 min read

Form 26 Against Form 3CD: Every Clause Mapped, and What Form 26 Adds and Drops

Three forms become one. Most of it is familiar; the parts that are not are the reason to map it now.

In short
  • Form No. 26 replaces Forms 3CA, 3CB and 3CD for tax years beginning on or after 1 April 2026; reports for AY 2026-27 are still Form 3CD.
  • Most 3CD clauses carry into a Form 26 clause or schedule row, but excise and service tax audits, other-law demands and refunds, and the country-by-country report are no longer asked.
  • New disclosures include the accounting software and storage location, a 180-day split for depreciation, and counts of transactions missing from TDS statements.

Form No. 26 replaces three forms at once. The tax audit report in Form 3CA or 3CB and the statement of particulars in Form 3CD become one form under section 63 of the Income-tax Act, 2025, prescribed by rule 47 of the Income-tax Rules, 2026. It is 33 pages long, and much of it is familiar. The parts that are not familiar are the reason to read it clause by clause now.

When it applies

CBDT's FAQs settle the timing. Form No. 26 applies to tax years commencing on or after 1 April 2026 (FAQ 2). Forms 3CA, 3CB and 3CD continue for previous years relevant to assessment years up to 2026-27 (FAQ 6), so the reports due in September 2026 are still Form 3CD. The first Form 26 reports are for tax year 2026-27.

The due date keeps the familiar rule: one month before the return's due date under section 263(1), so 30 September where the return is due on 31 October, and 31 October where it is due on 30 November (FAQ 5).

The shape of the form

The notified form has four Parts and eleven schedules. As printed in the form:

  • Part A is the audit report where the accounts are audited under another law, the successor to Form 3CA.
  • Part B is the audit report where they are not, the successor to Form 3CB.
  • Part C is the particulars of the assessee, clauses 1 to 8.
  • Part D is the statement of particulars, clauses 9 to 53, in eleven sub-parts from General Information to Quantitative Details.

CBDT's FAQ 8 letters the Parts the other way round: Part A for the particulars, Part B for the statement, and Parts C and D for the two audit reports. The clause numbers are the same either way, so this page cites clauses by number.

Schedules are triggered only by a Yes (FAQ 15), but they form part of the audit report and must be verified by the auditor (FAQ 16). Every clause needs a Yes or No, even where the answer is No (FAQ 17). Every section reference in the form is to the Income-tax Act, 2025 and the Income-tax Rules, 2026, and none is to the Income-tax Act, 1961 (FAQ 7).

Clause by clause

Clause by clause

Form 3CD against Form 26

Search a clause number, a section or a word such as depreciation.

Form 3CDForm 26Subject
cl. 1–3cl. 1–3Name, address, PAN
cl. 4cl. 52(a)Indirect tax registration numbersNow the first table of the GST schedule.
cl. 5cl. 4Status
cl. 6, 7cl. 8(a)Previous year and assessment yearOne field: tax year.
cl. 8cl. 9Provision under which the audit is conductedSection 63; presumptive cases under sections 58(2) and 61(2); section 58(8).
cl. 8acl. 10Option for a concessional tax regimeSections 199 to 204.
cl. 9cl. 11Partners or members and profit-sharing ratios
cl. 10cl. 12, 8(b)Nature of business and changes in it
cl. 11cl. 13, 14Books of account and where they are keptClause 14 adds the accounting software, cloud or other storage with its IP address and country, compliance with Rule 46(8), and the backup server's address in India.
cl. 12cl. 19Presumptive profits included in the profit and loss account
cl. 13cl. 15, 17, 18Method of accounting, ICDS adjustments and ICDS disclosures
cl. 14cl. 16Valuation of inventoryDeviation measured against section 277.
cl. 15cl. 22Capital asset converted into stock-in-trade
cl. 16cl. 21Amounts not credited to the profit and loss accountThe schedule rows include escalation and export incentives (section 278), subsidies and grants, other income and capital receipts.
cl. 17cl. 23Land or building transferred below stamp duty valueSections 53 and 78.
cl. 18cl. 36DepreciationCBDT FAQ 26: assets split between used for less than 180 days and 180 days or more, without dates.
cl. 19cl. 34Deductions such as scientific research and specified businessThe schedule lists sections 44 to 47.
cl. 20cl. 27(a), 27(b)Bonus or commission, and employees' contributions27(a) sections 29, 31 and 32; 27(b) section 29(1)(e).
cl. 21cl. 26, 27(c), 27(d), 28, 30, 31, 51Amounts inadmissibleSplit by section: 26 expenditure on exempt income; 27(c) section 34; 27(d) section 35; 28 penalties; 30 cash payments, section 36(4); 31 deemed income, section 36(5); 51 TDS defaults, section 35(b)(i) and (ii).
cl. 22cl. 33(a)Interest not allowable under section 23 of the MSMED Act
cl. 23cl. 29Payments to specified personsSection 36(3).
cl. 24cl. 21Deemed income such as tea development and site restoration accountsRows for sections 48 and 49 in the clause 21 schedule.
cl. 25cl. 21Profits chargeable on remission or cessation of a liabilityRow for section 38 in the clause 21 schedule.
cl. 26cl. 32, 33(b), 33(c)Sums allowed only on actual paymentSection 37(2)(a) to (f); payments to micro and small enterprises beyond the MSMED Act time limit under 37(2)(g).
cl. 27(b)cl. 35Prior period income and expenditure
cl. 29Acl. 21Advance forfeitedRow for section 92(2)(h) in the clause 21 schedule.
cl. 29Bcl. 20Money or property received without or for inadequate considerationSection 92(2)(m).
cl. 30cl. 24, 25Borrowing and repayment on a hundiSection 106.
cl. 30Acl. 40Primary adjustment to transfer priceSection 170(1).
cl. 30Bcl. 41Limitation of interest deductionSection 177.
cl. 31cl. 45Loans, deposits, specified sums, receipts and repayments beyond the cash limitsSections 185(1), 186(1) and 188(1). CBDT FAQ 19: journal entries and other non-cash modes are reported through mode codes.
cl. 32cl. 37Brought-forward losses and depreciationSection 119 on change in shareholding; speculation losses under section 113.
cl. 33cl. 38Deductions under Chapter VI-AChapter VIII of the 2025 Act.
cl. 34cl. 49, 50TDS and TCS complianceCBDT FAQ 38: the number of transactions reported and not reported after the latest correction statement, and the amount not reported; 50(c) interest under section 398(3)(a).
cl. 35cl. 53Quantitative detailsCBDT FAQ 28: only for a trading unit or manufacturing concern, through a schedule.
cl. 36Acl. 21Deemed dividend receivedRow for section 2(40)(e) in the clause 21 schedule. Clause 48 separately asks about loans or advances paid under section 2(40)(e).
cl. 36Bcl. 21Payment on buy-back of sharesRow for section 2(40)(f) in the clause 21 schedule.
cl. 37cl. 8(c)Cost auditWith the impact of any disqualification or disagreement.
cl. 40cl. 8(d)Turnover, gross profit and other ratios, this year and last
cl. 42cl. 46Statements in Forms 61, 61A and 61BNow Forms 98, 165, 166 and 167, with the transactions not reported.
cl. 44cl. 52(b)Expenditure by GST registration statusRegistered, unregistered and exempt. CBDT FAQ 20: no longer reconciled with each expenditure entry.
no clausecl. 5, 6, 7Residential status, email and contact number
no clausecl. 39Utilisation of MAT or AMT credit
no clausecl. 42Head office expenditure of a non-resident disallowable under section 60
no clausecl. 43Remittances reported in Part D of Form 145CBDT FAQ 27.
no clausecl. 47Transactions in unquoted shares
no clausecl. 48Loans or advances paid under section 2(40)(e)
cl. 27(a)not askedCENVAT and input tax credit and their treatmentNo clause or schedule of Form 26 names it.
cl. 30Cnot askedImpermissible avoidance arrangementNo clause or schedule of Form 26 names it.
cl. 38, 39not askedCentral excise and service tax auditsClause 8(c) asks only about a cost audit.
cl. 41not askedDemands raised and refunds issued under other tax lawsNo clause or schedule of Form 26 names them.
cl. 43not askedCountry-by-country reportNo clause or schedule of Form 26 names it.

Form 3CD clause numbers as for AY 2025-26. Form 26 clauses and schedules from the notified form under rule 47 of the Income-tax Rules, 2026, with sections checked against the Income-tax Act, 2025, and CBDT’s Form No. 26 FAQs.

What Form 26 adds

  • Where the books live. Clause 14 asks for the accounting software, any cloud or other storage with its IP address and country, whether Rule 46(8) has been complied with, and the address of the backup server in India. FAQ 18 ties this to Rule 46: books kept electronically must remain accessible in India, with a daily backup on servers located in India.
  • Depreciation without dates. Clause 36 splits assets between those used for less than 180 days and those used for 180 days or more, with no date of putting to use (FAQ 26).
  • What is missing from TDS statements. Clause 50 asks for the number of transactions reported and not reported in the TDS or TCS statement as it stands after the latest correction, and the amount not reported (FAQ 38).
  • Remittances. Clause 43 is limited to remittances actually reported in Part D of Form No. 145, the successor to Form 15CA (FAQ 27).
  • Credits and other new questions. Clause 39 asks about utilisation of MAT or AMT credit, clause 42 about head office expenditure disallowable under section 60, clause 47 about transactions in unquoted shares, and clause 48 about loans or advances paid under section 2(40)(e).
  • Qualifications that sort themselves. In the audit reports, every observation or qualification has to be put into one of three categories: test-check basis applying materiality, based on management representation, or unable to verify (FAQ 35). Paragraph 3 asks for the impact on profit, loss or book profit of the observations, qualifications, adverse remarks, disclaimers or emphasis of matter in the statutory audit (FAQ 36).
  • GST without the reconciliation. Clause 52(b) asks for expenditure relating to registered suppliers, unregistered suppliers and exempt goods or services, and FAQ 20 says it no longer needs to be reconciled with each entry of expenditure.

What Form 26 no longer asks

Read against the full text of the form, schedules included, five Form 3CD subjects appear nowhere: the CENVAT and input tax credit clause, impermissible avoidance arrangements, central excise and service tax audits, demands raised or refunds issued under other tax laws, and the country-by-country report.

Two things in the notified form to read carefully

The Parts. As set out above, the form and CBDT's FAQ 8 letter the Parts differently. Build working papers to the form.

Schedules 20 and 21. In the form, clause 20 is income under section 92(2)(m) not credited to the profit and loss account, and clause 21 is every other amount not credited. The schedule tables that follow carry those subjects the other way round: the table numbered 20 lists deemed dividend, buy-back payments, advance forfeiture and the other items, and the table numbered 21 carries section 92(2)(m). The clause wording is what the schedule answers to.

For this year

The reports being signed for AY 2026-27 are still Form 3CD, due on 30 September 2026. The Form 26 season is the next one, and the clause map above is the list to prepare against.

Questions this answers

From when is Form 26 applicable?

For tax years commencing on or after 1 April 2026. Forms 3CA, 3CB and 3CD continue for assessment years up to 2026-27.

Which Form 26 clause corresponds to clause 18 of Form 3CD on depreciation?

Clause 36. CBDT's FAQ 26 says assets are split between those used for less than 180 days and 180 days or more, without dates.

Which Form 26 clause replaces clause 44 of Form 3CD?

Clause 52(b), in the GST schedule, which asks for expenditure relating to registered suppliers, unregistered suppliers and exempt goods or services.

What is the due date for Form 26?

One month before the return's due date under section 263(1): 30 September where the return is due on 31 October, and 31 October where it is due on 30 November.

Does Form 26 refer to sections of the Income-tax Act, 1961?

No. CBDT's FAQ 7 says all references in Form No. 26 are to the Income-tax Act, 2025 and the Income-tax Rules, 2026.

Look up any section

The Income-tax Act 2025 section finder lists every 1961 TDS and TCS section with its 2025 section and Table serial, the rate and threshold as enacted, and the page of the Act, with a TDS rate chart and a TCS rate chart.

Where Audcrix runs this

  • DisallowancesEvery rupee add-back in one place — 43B(h) MSME invoice by invoice with Udyam verification, 40A(3) cash, 40(a)(ia) TDS defaults, 36(1)(va) and 14A with Rule 8D.
  • Income Tax ComplianceIncome-tax sections walked against the client's profile — 269SS, 269T and 269ST per ledger, a mode-wise 269ST register, the 44AB cash test and a taxable-income bridge.