What disallowances are reported in a tax audit?

Short answerThe tax audit doesn’t disallow anything by itself — Form 3CD reports the facts that make disallowances automatic in your computation. The big four: TDS defaults (30% of the expense under 40(a)(ia) for resident payees; 100% for foreign payments under 40(a)(i)), cash payments over ₹10,000 a day per person (40A(3)), unpaid statutory dues at the due date (43B), and employees’ PF/ESI deposited late — which is lost permanently.

The clauses that move real money

40(a)(ia): fail to deduct or deposit TDS on rent, professional fees, contracts — 30% of that expense is added back (claimable in the year the TDS is finally paid). 40A(3): any expense paid in cash beyond ₹10,000 to one person in a day is gone entirely. 43B: GST, employer PF, bonus, leave encashment and interest to banks count only when actually paid — paid-by-return-due-date items survive, the rest wait for payment year.

The one with no second chance

Employees’ own PF/ESI contributions deducted from salary must reach the fund by the fund’s due date — the Supreme Court’s Checkmate ruling settled that late deposit means permanent disallowance under 36(1)(va), with no 43B rescue. The 3CD table of month-wise deposits is where assessments now start; a payroll calendar aligned to the 15th solves it completely.

Related parties, and the era change ahead

Clause by clause, 3CD also surfaces 40A(2)(b) payments to relatives and group entities (excessive portions disallowable), delayed MSME payments, and GST-linked reconciliations — the auditor reports, the computation and the AO act. For FY 2025-26 (AY 2026-27) this world is still Forms 3CA/3CB-3CD under the 1961 Act; from Tax Year 2026-27 the audit moves to section 63 of the Income-tax Act, 2025 with a single consolidated Form 26. Clean ledgers travel well across both eras — our tax-audit practice builds the trackers that keep every clause nil.

Talk to CA Vijay R Singh

TDS, cash and PF clauses all green – or is the 3CD about to say otherwise? You can message him directly, or book a short call to talk through your situation.

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This answer is general information, not professional advice. Tax rates, thresholds and forms change with each Finance Act — please confirm the current position for your own facts, or speak to us, before acting.

© 2026 Vijay R Singh & Co., Chartered Accountants · FRN 136869W · ICAI M.No. 153926 · Practising since 2013

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