Date: 26 September 2026

Subject: Guidance on Generation of UDIN for Tax Audit Reports under Section 44AB and Transfer Pricing Reports under Section 92E – Assessment Year 2026-27

Dear Colleagues,

As the tax audit season for Assessment Year 2026-27 progresses, this circular sets out the procedure for generating the Unique Document Identification Number (UDIN) on the ICAI portal (udin.icai.org) for tax audit reports. It explains each field of the generation form, when each option applies, and the reporting elements under the Standards on Auditing that must be declared. Specimen paragraphs are given in the Annexure. All members of the team are requested to follow this guidance so that every UDIN generated by the firm is accurate and validates on the Income-tax e-filing portal without difficulty.

The UDIN is a mechanism introduced by the Institute of Chartered Accountants of India (ICAI) to register every certificate, report and document attested or certified by a Chartered Accountant in practice. Its purpose is to prevent misrepresentation of documents and to enable stakeholders to verify their authenticity.

A UDIN is an 18-character alphanumeric number:

•         the first two digits denote the year;

•         the next six digits are the member's ICAI membership number; and

•         the remaining ten characters are system-generated.

For tax audit reports, the Income-tax e-filing portal validates the UDIN against the ICAI database. The particulars entered at the time of generation must correspond exactly with the report uploaded. Any discrepancy will result in validation failure.

2.1 Member Details

The top panel of the form displays the member's name, membership number, registered e-mail address, PAN and pincode. These are drawn automatically from ICAI records and cannot be edited on this screen. Any correction must be made through the ICAI Self-Service Portal (SSP) before the UDIN is generated. The OTP for generation is sent to the member's registered mobile number and e-mail address.

2.2 Firm Registration Number (FRN)

Meaning. This field records the firm on whose behalf the report is signed. Every UDIN generated under an FRN is visible to the partner in-charge of that firm, which enables the firm to maintain a complete register of documents signed by its partners.

When to select an FRN. An FRN must be selected whenever the report is signed as partner or proprietor of a firm, on the firm's letterhead, with the firm's name and FRN in the signature block. This is the position in almost all tax audits. The FRN selected must be that of the firm named on the signed report.

When to select "Not Applicable / Individual Capacity". This option applies where the member signs in an individual capacity. As the form itself notes, it may also be used where the member is unable to generate the UDIN under the FRN category, for example due to a technical issue or an FRN linkage error. In that event, the firm's name and FRN must be entered in the "Document Description" field so that the link to the firm is preserved.

Practical points. A member who is a partner in more than one firm will see each firm's FRN in the dropdown, and must select the firm named on the signed report. The FRN on the UDIN, in the report's signature block and on the e-filing portal must be identical.

3.1 Document Type

"Tax Audit" is the appropriate selection for reports under Section 44AB and Section 92E. The other categories apply as follows:

•         Certificates and Other Reports: certificates such as net worth certificates and Form 15CB.

•         Audit and Assurance Functions: statutory audits, bank audits and internal audits.

3.2 Particulars of Section / Form under which Report is Issued

3.2.1 Choice between Form 3CA and Form 3CB

The first decision is whether the report is to be furnished in Form 3CA or Form 3CB. This depends on whether the assessee's accounts are required to be audited under any law other than the Income-tax Act.

Form 3CA is used where the accounts are required to be audited under another law. The tax auditor furnishes Form 3CA along with Form 3CD, relying on that audit. Common cases:

•         companies audited under the Companies Act, 2013;

•         LLPs whose turnover exceeds ₹40 lakh or whose contribution exceeds ₹25 lakh, audited under the LLP Act, 2008;

•         co-operative societies audited under the relevant co-operative societies law;

•         trusts and societies whose audit is mandated by the applicable State law; and

•         banks, insurance companies and statutory corporations audited under their governing statutes.

Form 3CB is used where no other law requires an audit. The tax auditor is then the only auditor, and the report covers both the true and fair view of the accounts and the particulars in Form 3CD. Common cases:

•         individuals carrying on business or profession, including proprietorships;

•         partnership firms;

•         Hindu Undivided Families;

•         LLPs below the statutory audit thresholds; and

•         AOPs and BOIs not subject to audit under any other law.

The dropdown lists each clause of Section 44AB separately under both forms. The correct form is chosen first, followed by the applicable clause.

3.2.2 Section 44AB(a): Business Turnover Exceeding the Threshold

When applicable. Clause (a) applies to a person carrying on business whose total sales, turnover or gross receipts exceed ₹1 crore in the year.

Enhanced threshold of ₹10 crore. The threshold rises to ₹10 crore where both of the following conditions are met:

•         aggregate cash receipts do not exceed 5% of total receipts; and

•         aggregate cash payments do not exceed 5% of total payments.

Receipts or payments by cheque or bank draft that are not account-payee are treated as cash for this purpose.

Exclusion. The audit requirement does not apply to a person who declares profits under Section 44AD(1) and whose turnover is within the limit specified for that section.

Use in practice. This is the most common clause, applicable to traders, manufacturers, contractors and other businesses whose turnover crosses the threshold.

3.2.3 Section 44AB(b): Professional Receipts Exceeding ₹50 Lakh

When applicable. Clause (b) applies to a person carrying on a profession whose gross receipts exceed ₹50 lakh in the year. There is no enhanced threshold based on cash transactions under this clause. (The ₹75 lakh limit applicable where cash receipts do not exceed 5% relates to presumptive taxation under Section 44ADA, not to the tax audit threshold.)

Scope. "Profession" covers the professions referred to in Section 44AA(1) and those notified under it. These include legal, medical, engineering, architectural, accountancy, technical consultancy, interior decoration, film artists, company secretaries and information technology.

Use in practice. This clause applies to doctors, advocates, architects, consultants and similar professionals whose receipts exceed ₹50 lakh. Where a person has both business and professional income, each threshold is tested separately.

3.2.4 Section 44AB(c): Presumptive Business under Sections 44AE, 44BB or 44BBB with Lower Income Claimed

When applicable. Clause (c) applies to a person carrying on a business covered by one of the following schemes, who claims profits lower than the presumptive amount:

•         Section 44AE: plying, hiring or leasing of goods carriages, for persons owning not more than ten goods vehicles;

•         Section 44BB: a non-resident providing services or facilities in connection with prospecting for, or extraction or production of, mineral oils; and

•         Section 44BBB: a foreign company engaged in civil construction for turnkey power projects approved by the Central Government.

Use in practice. This most often arises for transporters under Section 44AE who declare income below the presumptive rate per vehicle.

3.2.5 Section 44AB(d): Presumptive Profession under Section 44ADA with Lower Income Claimed

When applicable. Clause (d) applies to a professional eligible for presumptive taxation under Section 44ADA who meets both of the following conditions:

•         the professional claims profits lower than 50% of gross receipts; and

•         total income exceeds the maximum amount not chargeable to tax.

Use in practice. Consider a professional whose receipts are within the Section 44ADA limit (₹50 lakh, or ₹75 lakh where cash receipts do not exceed 5%). If that professional declares income below 50% of receipts and has taxable income, an audit is required under this clause, even though receipts are below the clause (b) threshold.

3.2.6 Section 44AB(e): Opting Out of Section 44AD

When applicable. Clause (e) applies to a person carrying on business to whom Section 44AD(4) applies and whose total income exceeds the basic exemption limit.

Section 44AD(4) applies where an assessee who opted for the presumptive scheme in one year declares profits otherwise than under Section 44AD in any of the next five years. Such an assessee is then barred from the scheme for the following five years.

Use in practice. This clause is selected for a small business that has exited Section 44AD within the five-year lock-in and has taxable income. The audit is required even though turnover is below the clause (a) threshold.

3.2.7 Form 3CEB: Section 92E (Transfer Pricing)

Meaning. Form 3CEB is the report of an accountant under Section 92E for persons who have entered into international transactions or specified domestic transactions. It certifies particulars of those transactions and whether the arm's length price has been determined in accordance with the prescribed methods.

When applicable. The report is required where either of the following applies:

•         the assessee has entered into any international transaction with an associated enterprise, with no monetary threshold; or

•         the assessee has entered into specified domestic transactions aggregating more than ₹20 crore in the year.

Due date. Form 3CEB is to be furnished one month before the due date of the return under Section 139(1). For such assessees that return due date is ordinarily 30 November, so Form 3CEB is ordinarily due by 31 October, unless extended.

Use in practice. Form 3CEB is a separate report and requires its own UDIN. Where an assessee requires both a tax audit report and a transfer pricing report, separate UDINs are to be generated for each.

3.2.8 Other Options

The dropdown also lists other reports under the Income-tax Act. The same principle applies throughout: select the exact form and section under which the report is signed, and ensure that the particulars match the report uploaded on the e-filing portal.

3.2.9 Summary of Selection

In each tax audit case, Form 3CA is selected where the accounts are audited under another law, and Form 3CB where they are not.

3.3 UDIN Generated For

"Original form/report" is selected for a first-time report. "Revised form/report" is selected only where a report already furnished is being revised, in which case reference to the original UDIN is ordinarily required.

3.4 Nature of Tax Audit Assignment

•         Assessee: the audit covers the assessee as a whole. This is the usual case.

•         Head Office of assessee: the member audits the head office, while the branches are audited by other auditors.

•         Branch of assessee: the member is appointed as branch auditor.

3.5 Assessment Year

Assessment Year 2026-27 corresponds to Financial Year 2025-26, which continues to be governed by the Income-tax Act, 1961. Reporting in Forms 3CA/3CB/3CD under Section 44AB therefore remains appropriate. The Income-tax Act, 2025 applies from Tax Year 2026-27 onwards.

3.6 PAN of the Assessee

The PAN serves as the fifth parameter for validation on the e-filing portal. The other four parameters are the membership number, the form, the assessment year and the date of signing. An error of even a single character will render the UDIN invalid at the time of upload. The fourth character of the PAN identifies the status of the assessee and must be consistent with the Entity Type selected (see paragraph 5).

3.7 Date of Signing of Document

The date entered must be the exact date on which the report was signed, as the e-filing portal validates it. Future dates are not accepted. ICAI guidelines permit generation within a prescribed period after signing, currently 60 days for audit reports. As a matter of firm policy, however, the UDIN is to be generated on the date of signing, and in every case before the report is uploaded.

4.1 Applicability

Under paragraph 3 of Form 3CB, the auditor expresses an opinion on whether the financial statements give a true and fair view. The response to "Is Auditor's Opinion applicable to this audit report?" is therefore "Yes".

4.2 Nature of Opinion

The opinion selected must faithfully reflect the report as signed:

•         Unmodified Opinion: the report contains no qualifications or adverse observations.

•         Qualified Opinion: the report contains observations or qualifications under paragraph 3 or 5 of Form 3CB. Examples include closing stock taken as certified by the proprietor without physical verification, or cash expenditure not supported by vouchers.

•         Adverse Opinion / Disclaimer of Opinion: rarely encountered in tax audits.

Where the report contains qualifications, selection of "Unmodified Opinion" is incorrect.

4.3 The Four Reporting Elements under the Standards on Auditing

The form requires the member to declare whether the signed report contains any of four paragraphs prescribed by the Standards on Auditing. These declarations form part of the UDIN record and may be referred to in peer review and quality review.

4.3.1 Key Audit Matters (KAM) – SA 701

Meaning. Key Audit Matters are those matters which, in the auditor's professional judgement, were of most significance in the audit of the financial statements of the current period. Typical examples are complex revenue recognition, impairment of goodwill, valuation of inventory and provisions for litigation. For each matter, the auditor explains in a separate section why it was significant and how it was addressed.

Applicability. Communication of KAM is mandatory for audits of listed entities. It is otherwise required only where law or regulation so requires, or where the auditor elects to communicate them.

Position in a tax audit. The prescribed formats of Forms 3CA and 3CB make no provision for KAM, and the assessees ordinarily subject to tax audit are outside the mandatory scope of SA 701. The response is "No" in practically all tax audit cases.

4.3.2 Emphasis of Matter (EOM) – SA 706

Meaning. An Emphasis of Matter paragraph draws users' attention to a matter already appropriately presented or disclosed in the financial statements, which is of such importance that it is fundamental to users' understanding of them. It does not indicate any deficiency; it only directs attention to a significant disclosure.

Essential characteristics.

•         The matter must already be disclosed in the financial statements or the notes thereto.

•         The paragraph does not modify the opinion, and this is expressly stated in the report.

•         An Emphasis of Matter paragraph cannot substitute for a modified opinion. A misstatement requires a qualification.

Illustrative circumstances. Uncertainty regarding the outcome of significant litigation or a tax demand; a major catastrophe such as fire or flood; early application of a new accounting standard; and significant events after the balance sheet date.

Position in a tax audit. Such paragraphs are uncommon. The response is "Yes" only where the member has included such a paragraph in the report.

4.3.3 Other Matter – SA 706

Meaning. An Other Matter paragraph refers to a matter not presented or disclosed in the financial statements. It is included where the matter is relevant to users' understanding of the audit, the auditor's responsibilities or the auditor's report.

Distinction from Emphasis of Matter. An Emphasis of Matter paragraph relates to a matter within the financial statements. An Other Matter paragraph relates to a matter outside them, concerning the audit process or the report.

Illustrative circumstances.

•         Reliance on reports of branch auditors, particularly where the assignment is "Head Office of assessee".

•         Audit of the previous year's figures by another auditor.

•         Previous year's figures being unaudited.

•         Restriction on distribution or use of the report.

Position in a tax audit. The response is ordinarily "No". It may be "Yes" where the member, as head office auditor, relies on branch auditors' reports, or has otherwise included such a paragraph.

4.3.4 Material Uncertainty Related to Going Concern – SA 570

Meaning. The going concern assumption presumes that the entity will continue operations for the foreseeable future, generally not less than twelve months from the balance sheet date. A separate paragraph headed "Material Uncertainty Related to Going Concern" is required where all three of the following conditions are met:

•         events or conditions cast significant doubt on this assumption;

•         use of the going concern basis nonetheless remains appropriate; and

•         the uncertainty is adequately disclosed in the financial statements.

Indicative events or conditions. Recurring substantial losses and erosion of net worth; defaults in repayment of borrowings or classification of accounts as non-performing assets; negative working capital or operating cash flows; loss of a major customer, licence or key supplier; and pending legal proceedings that may impair continuance of the business.

Reporting consequences.

•         Disclosure adequate: the opinion remains unmodified, and a Material Uncertainty paragraph is included. The response is "Yes".

•         Disclosure inadequate: the opinion is qualified or adverse, with the basis stated. A separate Material Uncertainty paragraph is not used.

•         Going concern basis inappropriate: an adverse opinion is expressed.

Position in a tax audit. Such cases are uncommon but may arise for loss-making or financially distressed businesses. The response is "Yes" only where the report contains this paragraph.

4.3.5 Summary Comparison

None of the four elements modifies the opinion by itself. Where going concern disclosure is inadequate, however, the opinion is modified as explained in paragraph 4.3.4.

4.3.6 Distinction from Qualifications

Observations recorded under paragraph 3 or 5 of Form 3CB are qualifications, not Emphasis of Matter or Other Matter paragraphs. Examples are stock not physically verified, cash vouchers not produced, and balances subject to confirmation. They require selection of "Qualified Opinion" and do not by themselves warrant a "Yes" response to any of the four elements.

4.3.7 Mapping the Report to the UDIN Form

The entity type must correspond to the status indicated by the fourth character of the assessee's PAN:

The form next requires key financial figures from the audited financial statements, such as turnover or gross receipts, net profit or loss, and total assets or capital. These must be entered exactly as reported in the financial statements and in Form 3CD, in rupees without paise.

After a brief description of the document is entered, the UDIN is generated upon OTP verification through the member's registered mobile number and e-mail address.

1.       The UDIN must be stated on the signed report, together with the member's signature, membership number and the firm registration number.

2.       The same UDIN must be furnished when uploading the report on the Income-tax e-filing portal. The portal also provides a facility to update the UDIN subsequently where required.

3.       Where a UDIN has been generated with incorrect particulars, it must be revoked on the ICAI portal, with reasons recorded, and a fresh UDIN generated. A UDIN bearing incorrect particulars must not be used.

4.       The list of UDINs generated on the portal is to be maintained as the firm's register for peer review and quality review.

•         Selecting an incorrect FRN, or generating the UDIN in individual capacity without recording the firm details in the Document Description.

•         Selecting Form 3CA in place of Form 3CB, or an incorrect clause of Section 44AB.

•         Typographical errors in the PAN, or a date of signing differing from that on the report.

•         Selecting "Unmodified Opinion" where the report contains qualifications.

•         Answering "Yes" to KAM, EOM, Other Matter or Material Uncertainty where the report contains no such paragraph, or "No" where it does.

•         Selecting an entity type inconsistent with the PAN.

•         Generating the UDIN after filing the report, or using a single UDIN for more than one assessee or more than one report.

•         Using one UDIN for both the tax audit report and Form 3CEB.

Consider the tax audit of an individual proprietor with PAN AZAPS9112N for Assessment Year 2026-27, whose business turnover exceeds the Section 44AB(a) threshold and whose report was signed on 20-09-2026 with no qualifications. The correct entries are:

All team members are requested to go through this circular carefully and to refer any doubt to the signing partner before generating the UDIN. The UDIN particulars should be cross-checked against the signed report and Form 3CD in every case before the report is uploaded.

With regards,

For [Firm Name]

Chartered Accountants

FRN: [______]

(CA [Name])

Partner

M. No. [______]

Place: Ghaziabad

Date: 26 September 2026

The following specimens are for guidance only. They must be adapted to the facts of each case and included only where the circumstances genuinely exist. In Form 3CB, such paragraphs are written in the space provided for observations under paragraphs 3 and 5, or as a separately headed paragraph immediately after the opinion in paragraph 3. Each must carry its own heading so that it is clearly distinguishable from a qualification.

A. Key Audit Matters (SA 701)

Generally not applicable to Form 3CB; included for completeness.

B. Emphasis of Matter (SA 706)

Specimen B-1: Pending tax demand

Specimen B-2: Loss due to fire

C. Other Matter (SA 706)

Specimen C-1: Reliance on branch auditors

Specimen C-2: Previous year audited by another auditor

D. Material Uncertainty Related to Going Concern (SA 570)

E. Qualifications (for contrast)

These change the Auditor's Opinion to "Qualified" and are not Emphasis of Matter or Other Matter paragraphs.