# Form 3CD amended for AY 2026-27 tax audit deadline 30 September

2026-09-21T18:36:48+00:00 | Governance | Indian Opinion Desk

Corroboration: 1 independent outlet

Tax audit for assessment year 2026-27 must be completed by 30 September 2026, with ITR filing due by 31 October. Forms 3CA, 3CB and 3CD continue to apply, but the Income Tax Department has made several changes to Form 3CD effective from April 2025. Key amendments cover reporting of MSME payments, loans and deposits, legal contraventions, and share buybacks. Clause 22 now requires a three-way split of MSME payables: total amount due, amount paid within the MSMED Act's 15- or 45-day window, and amount unpaid and inadmissible. Clause 31 replaces free-text loan descriptions with mandatory nature codes A through L. A new Clause 36B requires disclosure of buyback proceeds treated as deemed dividend under Section 2(22)(f). Clauses 28 and 29 on share premium and gifts have been removed, as these are now tracked in ITR forms directly. Auditors can revise a report under Rule 6G(3) if a post-filing payment curing a disallowance is made before the ITR due date. Taxpayers are advised to reconcile MSME ledgers and document settlements and buyback transactions ahead of the September deadline.

## Indian Opinion Analysis

The Form 3CD changes tighten compliance on two fronts the tax department has been watching closely. MSME payments now carry a strict 15- or 45-day deductibility window, mirroring the MSMED Act, and the new nature-code system for loans removes the ambiguity that let some taxpayers gloss over non-cash adjustments. The buyback clause, inserted after the 2024 budget shifted buyback taxation from the company to the shareholder, forces individual recipients to report deemed dividend income, which will directly affect their personal tax computation. Taxpayers with cross-border operations also face expanded disclosure of expenditure linked to foreign-law contraventions. With the audit deadline set for 30 September, the real pressure is on businesses to classify each vendor as micro, small or other, and to map every loan movement to one of 12 codes before the report is signed off.

## Coverage

- livemint.com <https://www.livemint.com/money/personal-finance/tax-audit-for-ay-2026-27-key-changes-in-form-3cd-you-should-know-before-30-september-deadline-11789995720810.html>

Tags: Form 3CD, income tax department, MSMED Act, Section 43B
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