Manner of revision of tax audit reports

Author note

I was working on tax audit’s of one of my client’s, after submitting the report management wanted to make changes in few estimates, It was my first time, hence thought to discuss my research with everyone

Introduction

We all know that tax audit is one of the important compliances under the Income-tax Act, 1961, the tax audit report is very important document for a company, as it serves as an authenticated certification by a chartered accountant on the correctness of particulars relating to an assessee’s business or profession. However, when we see practically, the circumstances sometimes necessitate revision of an already-filed tax audit report, whether due to post-audit changes in financial statements, clerical errors, technical glitches, or reinterpretation of data.

The Income-tax rules now expressly recognise this concept through Rule 6G(3) which was inserted via the Income-tax (eighth amendment) rules, 2021. Yet, many of us continue to face uncertainty regarding the legal permissibility of such revision, the procedure, and the UDIN (unique document identification number) related implications, along with professional risks.

What is Rule 6G(3)?

Rule 6G(3) states “the report of audit of the accounts of a person required by section 44AB shall be furnished in the following forms, namely (a) audit report in Form No. 3CA in case where the accounts of the business or profession of a person have been audited under any other law for the time being in force; or (b) audit report in Form No. 3CB in the case of a person referred to in clause (a) of section 44AB. The statement of particulars required to be furnished under section 44AB shall be in Form No. 3CD”.

In this article I will discuss each and every aspect of revision of tax audit, will be glad to see your queries and doubts related to the same in the comments below

Section 44AB of the income-tax act, 1961

Section 44AB mandates every person carrying on business or profession whose turnover, sales, or receipts exceed the prescribed limit to get their accounts audited by a practising chartered accountant and to furnish an audit report in the prescribed form.

Prescribed limit as on date of publication of this article is for a business, if the turnover, sales or gross receipts exceed Rs. 1 crore in the previous year or if the cash receipts/payments are 5 % or less of the total, then the threshold rises to Rs. 10 crore, while for a profession if the gross receipts exceed Rs. 50 lakhs in the previous year.

As we discussed above, the rule 6G in it’s Sub-rule (1) and (2) prescribed the forms and in that, the sub-rule (3) was inserted w.e.f. 1 April 2021, which specifically provided for revision of the audit report in limited circumstances, it’s bare act says:-

“The report of audit furnished under this rule may be revised by the person by getting revised report of audit from an accountant, duly signed and verified by such accountant, and furnish it before the end of the relevant assessment year… if there is payment by such person after furnishing of report… which necessitates recalculation of disallowance under section 40 or section 43B.”

Hence this rule legally allowed the revision where subsequent transactions or decisions after the original filing affect computation as per section 40 or section 43B.

Note: Section 40 disallows specified expenses like unpaid TDS, excessive payments to related parties, etc. from deduction if conditions are not met or payments are improper, while section 43B allows deduction for certain expenses like taxes, PF/ESI, interest to banks only on actual payment, irrespective of accounting method.

Circumstances warranting revision

Although when we take out literal interpretation of above paragraph as I stated above, it simply allows the revision when issue is related to post-payment adjustments governed by sections 40/ 43B, but practically is also recognises other bona-fide grounds as well.

Let’s discuss it with examples when tax audit report can be revised

Firstly, when the payments are made after original audit which impact allowable expenditure such as statutory dues, interest, employee benefits, etc, next one is when the revised financial statements approved after AGM or restated due to error or oversight, thirdly, when the changes are due to retrospective amendments in law or judicial interpretations, fourthly when there is a correction of clerical or technical errors such as incorrect PAN, clause mis-tagging, data entry issues, and last one is when the software/utility updates requiring re-uploading of corrected data.

In the ICAI’s guidance note on tax audit u/s 44AB, the institute clarified that the revision is not ordinarily desirable, it may be permissible only when accounts are themselves revised or when other justified circumstances exist. Proper disclosure of reason and cross-reference to the original report is mandatory.

In my case there was a justifiable reason of error in utility, hence I was able to revise the same.

Process of revising tax audit report

First of all one must identify the need for revision that means you must assess whether the reason falls under Rule 6G(3) or under other bona-fide professional grounds, and it it aligning with ICAI guidance note, document the same in writing pre-revision. Then you must obtain a written consent from the assessee for revising the report, The revised report shall be treated as a separate engagement as per the professional ethics.

After this, you must re-prepare the form 3CA/3CB and Form 3CD incorporating corrected particulars or recalculated disallowances. This must be done after clearly mentioning that “This is a revised report superseding the report dated DD/MM/YYYY, revised due to so & so reason.”

It must be noted that the revised report must be freshly signed, dated, and verified by the Chartered Accountant. The date of signing shall be the current date and not the date of the earlier report, also a fresh UDIN shall be generated irrespective of any change in UDIN numbers, then after that you must upload the revised audit report on the e-filing portal using the same PAN and assessment year, by selecting the “Revised/Replacement” or “Others” option (as enabled). Ensure client’s acceptance of the new report on the portal.

Documents to be maintained

Documents like the copy of the original and revised reports, client’s correspondence, UDIN details (old and new), Screenshots/acknowledgements of upload, and working papers supporting changes, make sure you take up fresh management representation as well for revised tax audit report.

Timeline and limitation

Under Rule 6G(3), the revised audit report must be furnished before the end of the relevant assessment year, that means for Fy 2024-25 or Ay 2025-26, revision can be filed anytime up to 31 March 2026. Beyond this, the Income-tax portal may not accept revision unless directed by the assessing officer.

Who should file for revised return?

where a tax audit report requires revision, the same auditor should revise and re-upload the Form 3CD with a suitable reason, in case a different auditor is to take over, the outgoing auditor must first be formally communicated and consent obtained as per ICAI ethical guidelines, the earlier report must be withdrawn, and the company/assessee must pass a resolution/letter of appointment for the new auditor. The incoming auditor then conducts necessary procedures afresh and issues a fresh audit report, as revision of the previous report by another auditor is not permissible.

As per ICAI guidelines, the same auditor must revise the tax audit report. A new auditor cannot revise it, instead, proper communication with the previous auditor, formal appointment, and fresh audit procedures are required if there is a change.

if the old auditor ceases to be in practice or has surrendered his COP, in that case he no longer holds eligibility to act as auditor or revise the earlier tax audit report. In such a case, the assessee may appoint a new auditor after complying with ICAI communication norms (to the extent possible), document the fact that the previous auditor is no longer in practice, and the new auditor will issue a fresh tax audit report, not a revision of the earlier one. Proper working papers, appointment resolution/letter, and justification for change must be maintained, as the revised report procedure by the earlier auditor is not possible once COP is surrendered.

Practical issues

Legal ambiguity which is beyond sections 40/43B

Rule 6G(3) explicitly covers revision only when payment after original report affects sections 40/43B disallowances. However, practically like in my case, the requirement for revision arose dueto other genuine reason, which lead to interpretational challenges. Even though prohibition dose not exists, the auditor must record adequate justification to defend professional conduct.

Disclosure requirements

Failure to disclose the reason for revision and reference to the earlier report may lead to professional negligence allegations under Clause 8 of Part I of Schedule II of the Chartered Accountants Act, 1949.

Impact on audit opinion

Where revision changes observations or qualifications, the revised report must explicitly state this. The revised opinion supersedes the earlier one completely.

Portal complications

At times, the e-filing portal does not display a distinct “Revised” option, causing confusion between new upload and replacement. Incorrect mapping may result in both reports reflecting, leading to departmental notices and queries.

Disciplinary and peer review exposure

Multiple or frequent revisions without adequate justification may raise questions on audit quality and could attract ICAI disciplinary review.

Also, I want to clarify that revised TAR does not auto-revise ITR, the assessee is required file a revised ITR separately referencing the new audit report.

Illustration

Aman Ltd. filed its tax audit report for FY 2024-25 on 25 October 2025 (As date was revised from 30th September to 31st October than to 10th November 2025). Subsequently, in December 2025, the company paid an outstanding employer’s PF contribution which was earlier disallowed u/s 43B. Since this payment changed the computation, the tax auditor revised Form 3CD to reflect the recalculated allowance. The revised audit report dated 03rd November 2025 was uploaded with a new UDIN and disclosure stating “Revised owing to payment of statutory dues u/s 43B.” The company later filed a revised ITR quoting the new audit report details.

Conclusion

The revision of tax audit reports is a legally recognised yet professionally sensitive process. The enabling clause under Rule 6G(3) provides a clear window for revision due to post-audit payments, however, other genuine revisions also hold validity if duly justified and transparently reported.

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