Disallowances are found by scanning expense ledgers for the usual suspects — cash, MSME dues, TDS defaults — and each one is usually worked in its own spreadsheet. Audcrix puts every rupee add-back in one place, listed under the section that triggers it, with the vouchers behind each figure.
Every add-back, section by section
- Section 40A(3) — expenditure paid in cash over the limit.
- Sections 40(a)(ia) and 40(a)(i) — TDS defaults carried from the TDS position.
- Section 43B — statutory dues not paid in time.
- Section 43B(h) — sums due to micro and small enterprises paid beyond the time the MSMED Act allows.
- Section 36(1)(va) — employee contributions to PF and ESI deposited late.
- Section 14A with Rule 8D, computed on the correct base.
- Section 37(1), and interest under section 201.
Section 43B(h), invoice by invoice
The MSME disallowance is computed invoice by invoice, not on the closing balance:
- The window applied per invoice — 15 or 45 days according to what is recorded about the agreement.
- Supplier status read from the Udyam certificate where one has been provided, so micro, small and medium enterprises are distinguished on evidence.
- Wholesale and retail traders kept outside section 15 of the MSMED Act, and therefore outside section 43B(h), even though they hold a registration.
- Payments in the following year read from that year's books where it has been synchronised, so an invoice paid inside its window in April is correctly not disallowed.
The employee share, separated
PF and ESI ledgers are split into employer and employee shares before anything is computed. The employer share goes to section 43B(b); the employee share goes to section 36(1)(va), tested against the fund's due date. Ledger names are read well beyond the word "employee", because a missed employee-share ledger is the expensive direction of the error. Where a ledger genuinely cannot be split, it is flagged for the CA to route, and that choice drives the section, not just a label.
Evidence, not a list
Every add-back opens onto its own vouchers, carrying the party, the amount and the provision that triggered it. Where the evidence is not there — no certificate, no agreement on file — the row is stated as unresolved rather than assumed either way.
Questions CAs ask
How does Audcrix compute the section 43B(h) MSME disallowance?
Invoice by invoice, applying the 15- or 45-day window to each invoice, reading supplier status from the Udyam certificate, and checking next-year payments where that year has been synchronised.
Are traders registered on Udyam included in 43B(h)?
No. Wholesale and retail traders fall outside section 15 of the MSMED Act, so they are kept outside the section 43B(h) disallowance.
How are PF and ESI employee contributions handled?
The employee share is separated from the employer share and tested under section 36(1)(va) against the fund due date; the employer share goes to section 43B(b).
Further reading
Related modules
- TDS Intelligence — Deductee-wise TDS keyed to PAN — the real payee from each voucher, the right section, 194Q and 194T gates, month-wise deposits, and the 2025 Act's Table serials.
- Income Tax Compliance — Income-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.
- Detailed Scrutiny — Transaction-level voucher scrutiny across the whole Tally population — exception flags, period read from the narration, and prior-period items confirmed by the CA.
