Form 26 vs Form 3CD: the clause map for tax year 2026-27
Every Form 26 item matched to the Form 3CD clause it replaces — what carries forward, what is new, what is gone, and the three changes most summaries get wrong.
The Income-tax Act, 2025 takes effect from 1 April 2026. For a business whose accounts must be audited, the report on the first tax year under the new Act — tax year 2026-27 — is no longer Form 3CA or 3CB with Form 3CD. It is Form 26. The audit you sign this season, for FY 2025-26, is still on Form 3CD. The next one is not.
Most of what Form 26 asks, Form 3CD already asked. The work is in knowing exactly where each answer has moved, because last year's working papers are filed against the old clause numbers. This article is that map.
How Form 26 is laid out
Form 26 is one form in four parts. Parts A and B are the audit reports themselves — A where the accounts are already audited under another law (the old Form 3CA), B where they are not (the old 3CB). Part C carries the particulars of the assessee in clauses 1 to 8. Part D is the statement of particulars, clauses 9 to 53, and is where nearly all the tax-audit work lives.
Part D's clauses are gathered into schedules: General Information, Accounting Information, Computation of receipts and income, Computation of expenses, Prior period, Losses, depreciation and deductions, International taxation, Other key parameters, TDS/TCS, GST, and Quantitative details. The schedule tells you which working paper an answer belongs in.
Two changes run through the whole form. Section references are to the new Act, so 40A(3) is now cited as section 36(4), 43B(h) through section 37(2)(g), and 40(a)(ia) through section 35(b). And the period is the tax year: clause 8 asks only for that, where Form 3CD asked for both the previous year and the assessment year.
The clause map
The table lists the items where the correspondence is certain from the wording of both forms. Where the mapping is a judgement a CA could argue, it is left out of this table and listed separately below.
| Form 26 | Form 3CD | Subject |
|---|---|---|
| PART C · PARTICULARS | ||
| 1, 2, 3 | 1, 2, 3 | Name, address, PAN |
| 4 | 5 | Status |
| 8 | 6, 7 | Period — now the tax year alone |
| PART D · GENERAL AND ACCOUNTING INFORMATION | ||
| 9 | 8 | Provision under which the audit is required |
| 10 | 8a | Option for a concessional tax regime |
| 11(a), 11(b) | 9(a), 9(b) | Partners or members; change in them |
| 12(a), 12(b) | 10(a), 10(b) | Nature of business; change in it |
| 12(c) | 37 | Cost audit |
| 12(d) | 40 | Accounting ratios |
| 13, 14(a) | 11(b) | Books of account maintained |
| 15(a), 15(b) | 13(a), 13(b), 13(c) | Method of accounting; change and its effect |
| 16(a), 16(b) | 14(a), 14(b) | Valuation of closing stock; deviation from the prescribed method |
| 17, 18 | 13(d), 13(e), 13(f) | Income computation and disclosure standards |
| 19 | 12 | Presumptive income included in profit |
| PART D · RECEIPTS AND INCOME | ||
| 20 | 29B | Sums received without consideration |
| 21 | 16, 24, 25, 29A, 36A, 36B | Amounts not credited, deemed profits, s.41 receipts and similar items — now one clause |
| 22 | 15 | Capital asset converted into stock-in-trade |
| 23 | 17 | Land or building transferred below stamp value |
| 24, 25 | 30 | Amounts borrowed or repaid on hundi |
| PART D · EXPENSES AND DISALLOWANCES | ||
| 27(b) | 20(b) | Employees' contributions to PF and other funds |
| 29 | 23 | Payments to specified persons |
| 30 | 21(d)(A) | Cash payments above the limit (old 40A(3)) |
| 31 | 21(d)(B) | Later cash payment of an earlier year's expense (old 40A(3A)) |
| 32(a) | 26(B)(b) | Sums under old s.43B incurred in the year but not paid by the return due date |
| 32(b), 33(c) | 26(A)(a) | Sums of earlier years, disallowed then, paid in this year |
| 33(a) | 22(i) | Interest inadmissible under s.23 of the MSMED Act |
| 33(b) | 22(ii), 22(iii) | Dues to micro and small enterprises (old 43B(h)) |
| 34 | 19 | Amounts admissible as deductions |
| PART D · PRIOR PERIOD, LOSSES, DEPRECIATION | ||
| 35(a), 35(b) | 27(b) | Prior-period items |
| 36 | 18 | Depreciation |
| 37(a) | 32(a) | Brought-forward losses and depreciation |
| 37(b) | 32(b) | Change in shareholding affecting carry-forward |
| 37(c), 37(d), 37(e) | 32(c), 32(e), 32(d) | Speculation losses, deemed speculation, specified business |
| 38 | 33 | Deductions under Chapter VIII (old Chapter VI-A) |
| PART D · INTERNATIONAL AND OTHER KEY PARAMETERS | ||
| 40 | 30A | Secondary adjustment |
| 41(a)–(c) | 30B | Limitation of interest deduction |
| 45(a) | 31(a), 31(b) | Loans and deposits accepted in cash |
| 45(b), 45(c) | 31(ba)–31(bd) | Cash receipts and payments of ₹2 lakh or more |
| 46 | 42(a), 42(b) | Statements of financial transactions furnished |
| PART D · TDS/TCS, GST, QUANTITATIVE | ||
| 50(a) | 34(a) | Tax deductible or collectible, and what was done |
| 50(b) | 34(b) | Statements not furnished, or not with all transactions |
| 50(c) | 34(c) | Interest for late deduction or payment |
| 51(a) | 21(b)(ii) | Disallowance for TDS defaults on payments to residents |
| 52, 52(a) | 4 | Registrations under indirect-tax laws |
| 52(b) | 44 | Expenditure by GST status of the supplier |
| 53(a), 53(b) | 35(a), 35(b) | Quantitative details |
Mappings that are a judgement
Clauses 27(a), 27(c), 27(d) and 28 of Form 26 regroup the old clause 20(a) and parts of clause 21 — personal and capital expenditure, penalties, payments to partners, gratuity, contingent liabilities. Clause 45(d) gathers the old 31(c) to 31(e). Clauses 48, 49, 51(b) to 51(d) have no single predecessor. For these, read the new wording against your working paper rather than carrying the old answer across.
What is new
Several items have no Form 3CD predecessor at all and need fresh working: clauses 5, 6 and 7 of Part C; 14(b) to 14(e) on books and records, including two that cite section 46(8); 39 in the losses schedule; and 42, 43, 44 and 47 among the other key parameters. Plan for these before the season, not during it.
What is gone
Form 26 no longer asks for the Form 3CD subjects in clauses 11(a), 11(c), 27(a), 30C, 38, 39, 41 and 43, nor the clause 26 note on indirect taxes passed through the profit and loss account. Clauses 28 and 29 of Form 3CD were already omitted by the Income-tax (Eighth Amendment) Rules, 2025, and clause 36 in 2021.
Three changes most summaries get wrong
1. MSME dues were never in clause 26
After the 2025 amendment, Form 3CD reports amounts disallowed under section 43B(h) in clause 22(ii) and 22(iii), and clause 26(B) expressly excludes them. In Form 26 they sit in clause 33(b), beside the MSMED interest in 33(a). A working paper filed under "43B — clause 26" will put the MSME figures in the wrong place twice.
2. The GST split has three rows, not four columns
Form 3CD clause 44 broke expenditure into exempt supplies, composition dealers, other registered suppliers, and unregistered suppliers. Form 26 clause 52(b) asks for three rows: expenditure relating to entities registered under GST, to entities not registered, and to goods or services exempt from GST. Rebuild the working, don't relabel it.
3. Clause 12(c) and 12(d) are cost audit and ratios
Clause 12 gathers four general questions: the nature of business, any change in it, cost audit (old clause 37) and the accounting ratios (old clause 40). The ratios no longer stand at the end of the form; they sit in the General Information schedule.
How this map was checked
The map was built twice. One key was transcribed from the notified Form 26 and the amended Form 3CD; a second was built independently, without sight of the first. Every disagreement between them was resolved against the forms' own wording, or the item was moved to the judgement list above. The reconciled key is then used to grade software that claims to carry answers from 3CD to Form 26: Corelytix's catalogue passes all 467 checks.
What to do this season
- Finish FY 2025-26 on Form 3CD, but file each working paper with its Form 26 number beside the 3CD number.
- Move the 43B(h) working to clause 22 now; it becomes 33(b).
- Rebuild the GST expenditure working in the three-row form.
- List, client by client, the facts the new items will need — especially 14(b)–(e), 42 to 44 and 47 — and ask for them in this year's query letter.
This map reflects the forms as read on 18 October 2026. Check the current notified text before relying on it for a report you sign. Sources: Form No. 26, Income Tax Department; Form 3CD as amended by the Income-tax (Eighth Amendment) Rules, 2025.