- Why AY 2026-27 is a special compliance year
- Quick calendar at a glance
- Tax audit and transfer pricing due dates
- ICAI tax audit ceiling from 1 April 2026
- TDS and TCS return due dates for FY 2025-26
- Form 16, Form 16A and TCS certificate dates
- ITR due dates for AY 2026-27
- Advance tax dates after 1 April 2026
- Important Form 3CD changes professionals should note
- UDIN updates that matter in practice
- Related DN & CO. reads
- Frequently asked questions
- Official references
Why AY 2026-27 Is a Special Compliance Year
AY 2026-27 is one of those years where professionals cannot rely only on memory. Income of FY 2025-26 will still be returned under the Income-tax Act, 1961. However, from 1 April 2026, the new Income-tax Act, 2025 comes into force for the new tax-year framework. In other words, while you may still be filing old-law ITRs for AY 2026-27, you are simultaneously stepping into a new-law ecosystem for future-year forms, due dates, tax-year language and portal behaviour.
This is exactly why a CA’s compliance calendar for this cycle should not look like a recycled checklist. The filing year needs to be split into two parts: AY 2026-27 old-law obligations and post-1 April 2026 new-law transition obligations.
Quick Calendar at a Glance
| Compliance item | Relevant period | Due date | Practical note |
|---|---|---|---|
| TDS return Q4 - Forms 24Q, 26Q, 27Q | Jan-Mar 2026 | 31 May 2026 | TDS and TCS should not be merged here |
| TCS return Q4 - Form 27EQ | Jan-Mar 2026 | 15 May 2026 | Separate timeline from TDS returns |
| Form 16 | Salary TDS for FY 2025-26 | 15 June 2026 | Annual salary TDS certificate |
| ITR-1 / ITR-2 | AY 2026-27 | 31 July 2026 | Salaried and other non-business cases |
| ITR-3 / ITR-4 non-audit cases | AY 2026-27 | 31 August 2026 | Key due-date change |
| Tax audit report - Form 3CA/3CB + 3CD | AY 2026-27 | 30 September 2026 | One month before ITR due date for audit cases |
| ITR for audit cases | AY 2026-27 | 31 October 2026 | Includes standard audit cases |
| Form 3CEB | AY 2026-27 | 31 October 2026 | Transfer pricing report |
| ITR for transfer pricing cases | AY 2026-27 | 30 November 2026 | Separate higher deadline |
| Belated return | AY 2026-27 | 31 December 2026 | Subject to earlier completion of assessment |
| Revised return | AY 2026-27 | 31 March 2027 | Based on amended section 139 position |
Tax Audit and Transfer Pricing Due Dates
For AY 2026-27, tax audit continues to be filed under the Income-tax Act, 1961, even though the actual filing season falls after 1 April 2026. The transition FAQ issued by the Income Tax Department is explicit on this point.
Core dates every CA should anchor first
- Tax Audit Report in Form 3CA/3CB with Form 3CD: 30 September 2026
- ITR for audit cases: 31 October 2026
- Form 3CEB: 31 October 2026
- ITR for transfer pricing cases: 30 November 2026
If your team is already preparing for post-1 April 2026 form renumbering and process changes, it is worth reading DN & CO.’s practical guide on new income-tax forms and old-vs-new form mapping.
ICAI Tax Audit Ceiling from 1 April 2026
This is the most discussed professional-governance change in the current cycle. The Chartered Accountants (Limit on Number of Tax Audits) Guidelines, 2025, notified on 25 July 2025, come into force from 1 April 2026. They supersede the earlier guideline framework from that date onward.
| Point | Current position from 1 April 2026 |
|---|---|
| Basic ceiling | 60 tax audit assignments |
| Basis of counting | Financial year in which the report is signed |
| Firm position | 60 assignments per partner, not per firm as a pooled block |
| Cross-firm aggregation | Aggregate ceiling applies if the same partner is partner in multiple firms |
| Individual + firm capacity | Aggregate cap still applies |
| Excluded audits | Section 44AB audits arising from sections 44AD, 44ADA and 44AE are excluded from reckoning |
| Revised tax audit report | Not counted separately |
| HO and branch audits | Treated as a single assignment for the same entity |
Many professionals still remember the older ICAI council position of 60 audits as a familiar number, but the 2025 guidelines sharpen the counting mechanics and the compliance discipline around it.
TDS and TCS Return Due Dates for FY 2025-26
This is one of the easiest places where compliance summaries become inaccurate. Forms 24Q, 26Q and 27Q follow the TDS statement calendar. Form 27EQ follows the TCS statement calendar. They are not identical.
TDS statement due dates
| Quarter | Period | Forms | Due date |
|---|---|---|---|
| Q1 | Apr-Jun 2025 | 24Q / 26Q / 27Q | 31 July 2025 |
| Q2 | Jul-Sep 2025 | 24Q / 26Q / 27Q | 31 October 2025 |
| Q3 | Oct-Dec 2025 | 24Q / 26Q / 27Q | 31 January 2026 |
| Q4 | Jan-Mar 2026 | 24Q / 26Q / 27Q | 31 May 2026 |
TCS statement due dates
| Quarter | Period | Form | Due date |
|---|---|---|---|
| Q1 | Apr-Jun 2025 | 27EQ | 15 July 2025 |
| Q2 | Jul-Sep 2025 | 27EQ | 15 October 2025 |
| Q3 | Oct-Dec 2025 | 27EQ | 15 January 2026 |
| Q4 | Jan-Mar 2026 | 27EQ | 15 May 2026 |
For broader withholding compliance and future-year mapping under the new law, see DN & CO.’s TDS rate chart and due-date guide for FY 2026-27.
Form 16, Form 16A and TCS Certificate Dates
Return due dates attract attention, but certificate due dates are where many client complaints begin.
- Form 16: to be issued by 15 June 2026 for salary TDS of FY 2025-26
- Form 16A: to be issued within 15 days from the due date of furnishing the quarterly TDS statement
- Form 27D: TCS certificate is also linked to the due date of Form 27EQ and generally follows the same 15-day post-due-date principle
ITR Due Dates for AY 2026-27
The most meaningful due-date change for AY 2026-27 is the extension for non-audit business cases and trusts from 31 July to 31 August 2026. This is not a rumor-based extension. It was specifically explained in the Budget 2026 FAQ and reflected in the amended due-date framework.
| Return category | Indicative forms | Due date for AY 2026-27 |
|---|---|---|
| Salaried / non-business cases | ITR-1 / ITR-2 | 31 July 2026 |
| Business or profession, non-audit cases | ITR-3 / ITR-4 | 31 August 2026 |
| Audit cases | ITR-3 / ITR-5 / ITR-6 / eligible cases | 31 October 2026 |
| Transfer pricing cases | Applicable cases with Form 3CEB | 30 November 2026 |
| Belated return | Section 139(4) | 31 December 2026 |
| Revised return | Section 139(5) | 31 March 2027 |
Updated return
The updated-return window has already been expanded from 24 months to 48 months. This change is effective from AY 2026-27 under the old Act framework. For professionals, that means updated-return planning is no longer a narrow two-year backstop. It has become a more strategic post-filing correction tool.
Advance Tax Dates After 1 April 2026
The advance tax dates you are tracking for 15 June 2026, 15 September 2026, 15 December 2026 and 15 March 2027 belong to the post-1 April 2026 regime. These are not FY 2025-26 advance-tax dates. They relate to the new period beginning after the new Act comes into force.
| Instalment | Due date | Cumulative payment |
|---|---|---|
| 1st instalment | 15 June 2026 | 15% |
| 2nd instalment | 15 September 2026 | 45% |
| 3rd instalment | 15 December 2026 | 75% |
| 4th instalment | 15 March 2027 | 100% |
For presumptive-taxation taxpayers in the new-law framework, the one-instalment discipline by 15 March remains important. For a deeper transition-year explanation, see DN & CO.’s advance tax guide for Tax Year 2026-27.
Important Form 3CD Changes Professionals Should Note
This is the part where many summaries lose precision. The updated Form 3CD structure for the current cycle should be read carefully, especially if your team is using old clause memory from prior years.
1. Clause 22 is now more detailed for MSME reporting
Clause 22 does not stop at only disallowable MSME interest. It now also requires total amount payable to micro or small enterprises under section 15 of the MSMED Act and related bifurcation. This is a much more substantive disclosure requirement than many teams are budgeting time for.
2. Clause 21 now captures more than the older penalty language
Clause 21 now specifically extends to expenditure incurred to settle proceedings initiated in relation to contraventions under notified laws. In practical terms, “legal settlement spend” can no longer be brushed aside as a generic legal expense without classification review.
3. Clauses 28 and 29 are omitted
That omission is real. Teams carrying forward old 3CD checklists without updating templates are likely to create avoidable review confusion.
4. Clause 36A and Clause 36B should not be mixed up
- Clause 36A deals with amounts received in the nature of dividend under section 2(22)(e)
- Clause 36B deals with amounts received for buyback of shares under section 2(22)(f)
UDIN Updates That Matter in Practice
UDIN has moved well beyond being a last-minute formality. For tax audit and assurance work, the portal architecture and validation expectations matter operationally.
Verified practical points
- UDIN remains mandatory for tax audit reporting.
- For tax audit under section 44AB, the same UDIN is used across Form 3CA/3CB and Form 3CD for that assignment.
- ICAI’s UDIN system restricts revocation to 48 hours from the time of generation.
- ICAI announced additional capture of auditor’s opinion information at the UDIN portal under GST & Tax Audit and Audit & Assurance categories.
- The DigiCA UDIN portal manual indicates additional workflow capture relating to predecessor-auditor details and communication status in relevant cases.
Suggested internal SOP for firms
- Maintain a partner-wise real-time tax audit count from the start of the assignment season.
- Track sign-date planning, not only client acceptance planning.
- Keep predecessor-auditor communication records and follow-up support in the file.
- Freeze reporting positions, qualifications and disclosure issues before UDIN generation stage.
- Do not assume that a later correction can always be solved by revocation, because the 48-hour window is narrow.
Related DN & CO. Reads
- New Income Tax Forms 2026: Old vs New Forms Mapping Guide
- Advance Tax for Tax Year 2026-27: Due Dates, Sections 403 to 410 and Practical Payment Guide
- TDS Rate Chart FY 2026-27: Latest Section-wise TDS Rates and Due-Date Guide
- Bank Transaction Limits 2026: PAN, AIS, SFT and Cash Rule Guide
- Form No. 121 Explained: Practical No-TDS Guidance Under the New Framework
- Non-Resident TDS FY 2026-27: Section 393(2), DTAA, Rates and Compliance
Frequently Asked Questions
1. Is Q4 due date the same for TDS and TCS statements for FY 2025-26?
No. Q4 TDS statements in Forms 24Q, 26Q and 27Q are due on 31 May 2026, while Q4 TCS statement in Form 27EQ is due on 15 May 2026.
2. Has the non-audit business return due date really shifted to 31 August for AY 2026-27?
Yes. The shift to 31 August applies to non-audit business cases and trusts for AY 2026-27 under the amended framework.
3. Does AY 2026-27 filing happen under the Income-tax Act, 2025?
No. AY 2026-27 return filing for income of FY 2025-26 continues under the Income-tax Act, 1961. The new Act applies prospectively from 1 April 2026 for the new regime.
4. What is the due date for tax audit report for AY 2026-27?
For standard audit cases, the due date is 30 September 2026. For transfer pricing cases, the relevant report timeline extends to 31 October 2026.
5. Is Clause 36B the deemed dividend clause in Form 3CD?
No. Clause 36A covers dividend under section 2(22)(e). Clause 36B covers amount received for buyback of shares under section 2(22)(f).
6. Is the ICAI tax audit ceiling counted per firm or per partner?
The operative ceiling is partner-based. The 2025 guidelines apply the 60-assignment ceiling per partner, with aggregation across firms and individual capacity where relevant.
7. Can a revised tax audit report be counted again in the 60-audit limit?
No. The guidelines state that a revised tax audit report is not to be counted again for this purpose.
8. Can UDIN be revoked at any time if a mistake is noticed?
No. ICAI has restricted UDIN revocation to 48 hours from generation. That is why final pre-generation review matters.
Official References
- Income Tax Department: Updated FAQs on Interplay and Transition
- Income Tax Department: Return of Income guidance page
- Income Tax Department: Tax Collector page for Form 27EQ due dates
- Income Tax Department: Form 16 and Form 16A guidance
- Income Tax Department: Transfer Pricing guidance and Form 3CEB timeline
- Gazette copy: Chartered Accountants (Limit on Number of Tax Audits) Guidelines, 2025
- ICAI official announcement on the 60-tax-audit ceiling background
Final Professional Takeaway
The biggest mistake in this cycle is treating AY 2026-27 like a routine year. It is not. This is a transition season where old-law returns, new-law awareness, due-date changes, sharper tax audit counting rules and tighter UDIN discipline all sit on the same desk at the same time.
The firms that handle this year best will not necessarily be the firms that work the longest in September. They will be the firms that classify the calendar correctly, separate TDS from TCS, allocate audits partner-wise early, update Form 3CD review notes properly and run a clean transition playbook from June onward.