Understanding Rule 6G(3), ICAI guidelines, timelines, UDIN, and practical challenges
A tax audit is one of the most critical compliances under the Income-tax Act, 1961. The tax audit report (TAR) — either in Form 3CA/3CB along with Form 3CD — acts as a verified certification by a Chartered Accountant on the accuracy of financial particulars of a business or profession.
However, situations do arise where an audit report filed on the income-tax portal needs to be revised. These may be caused by post-audit changes in financial statements, late statutory payments, clerical errors, updated utilities, or re-interpretation of data.
For years, professionals debated whether revision of a filed tax audit report was legally permissible. The Income-tax (Eighth Amendment) Rules, 2021 finally resolved this through insertion of Rule 6G(3), which expressly recognises the concept of revision of tax audit reports.
Rule 6G(3) provides that:
“The report of audit furnished under this rule may be revised… before the end of the relevant assessment year, if there is a payment… after furnishing of the original report… necessitating recalculation of disallowance under section 40 or section 43B.”
In simple terms:
✔ If a tax audit report was filed
✔ and later the assessee makes a payment that affects disallowances under Section 40 or 43B
✔ the audit report may be revised within the same assessment year.
Audit under Section 44AB becomes mandatory if:
| Category | Threshold (as of date of this article) |
|---|---|
| Business | Turnover > ₹1 crore, or up to ₹10 crore where cash receipts & payments ≤ 5% |
| Profession | Gross receipts > ₹50 lakhs |
Although Rule 6G(3) specifically mentions revision due to Section 40/43B adjustments, professional practice and ICAI guidance recognize other valid grounds too.
Post-filing payment of statutory dues
– PF/ESI, GST, interest to banks, etc. impacting Section 43B/40 computation.
Revised or restated financial statements
– Post-AGM corrections, material adjustments, or audit committee directions.
Retrospective amendment in law or judicial ruling
– Causing change in tax treatment.
Clerical or technical errors
– Wrong PAN, clause mis-tagging, typing errors, wrong figures.
Utility or software corrections
– When portal or schema updates require fresh reporting.
ICAI’s Guidance Note says revision is not generally preferred, but allowed when:
✔ accounts themselves are revised, or
✔ there is a justified professional reason.
A clear disclosure and reference to the original report are mandatory.
Check whether it falls under Rule 6G(3) or other bona-fide justification
Keep written documentation before revision
Treat the revision as a separate audit engagement
Update the corrected particulars
Include remark:
✅ “This is a revised report superseding the report dated DD/MM/YYYY due to <reason>.”
New date of signing (not back-dated)
Generate a fresh UDIN
Upload the revised TAR under the same PAN and AY
Select “Revised/Replacement/Others” (as enabled)
Assessee must again approve the report online
Original & revised reports
Assessee communication & consent
UDIN trail
Working papers
Proof of upload
Fresh management representation letter
The revised report must be filed:
✔ Before the end of the relevant assessment year
Example:
For FY 2024-25 / AY 2025-26, revision is allowed till 31 March 2026.
Portal may not permit revision after that except on AO direction.
✔ Ideally, the same auditor who signed the original report.
A different auditor cannot revise the old report. If the assessee changes auditor:
✅ the outgoing auditor must be communicated
✅ the new auditor must carry out a fresh audit
✅ a completely new tax audit report is issued (not a revision)
If old auditor’s COP is surrendered/expired:
Revision is impossible by earlier auditor
Assessee appoints new auditor
New auditor issues a fresh report with proper documentation
| Issue | Explanation |
|---|---|
| Rule covers only Sec. 40/43B | But legitimate revisions arise due to other reasons too → professional judgment needed |
| Portal may not show clear “revised” option | Leads to duplication or wrong mapping |
| Disclosure lapses | Not stating reason for revision may attract action under CA Act |
| Peer Review / Disciplinary risk | Frequent unjustified revisions raise questions on audit quality |
| ITR does not auto-update | Revised TAR does not revise ITR — taxpayer must file revised ITR separately |
Revision of tax audit reports is:
✔ Legally valid,
✔ Portal-enabled, and
✔ Recognised under Rule 6G(3)
But — it is also a professionally sensitive exercise requiring proper documentation, disclosure, UDIN compliance, and adherence to ICAI’s ethical guidelines.
A well-recorded justification protects both the assessee and the auditor from future litigation and disciplinary risks.
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