top of page
CA India Logo.png

PGT & ASSOCIATES

Chartered Accountant Firm

Tax Audit Turnover Calculation AY 2026-27: Section 44AB 5% Cash Test & GST

Aug 23
6 min read

Updated: Sep 28

Direct answer: For FY 2025-26 / AY 2026-27, tax audit under section 44AB generally applies to a business when total sales, turnover or gross receipts exceed ₹1 crore. The threshold rises to ₹10 crore only when BOTH cash receipts and cash payments do not exceed 5% of their respective totals. Non-account-payee cheques and bank drafts are treated as cash for this test. Turnover itself must be computed carefully from the books and the nature of the business; it is not always the same as the gross value shown in invoices, bank credits or contract notes.

Update — 28 September 2026: CBDT changed the specified ordinary AY 2026–27 tax-audit report deadline from 30 September to 21 October 2026 and the related audited return deadline from 31 October to 21 November 2026. Transfer-pricing Form 3CEB cases follow a separate timeline. Official Income Tax Department announcement.

Why turnover calculation matters for AY 2026-27

A surprisingly common tax-audit error is to start with the ₹1 crore or ₹10 crore threshold before first deciding what belongs in sales, turnover or gross receipts. For businesses with discounts, indirect taxes, reimbursements, foreign-exchange differences, scrap sales, securities or derivative transactions, the wrong turnover base can lead to the wrong audit conclusion.

AY 2026-27 is also a transition year. The Income Tax Department has clarified that FY 2025-26 / AY 2026-27 continues under the Income-tax Act, 1961 and uses Forms 3CA or 3CB with Form 3CD. The ordinary tax-audit report due date is 21 October 2026. The new unified Form 26 applies from Tax Year 2026-27 under the Income Tax Act, 2025, not to FY 2025-26.

1. Section 44AB thresholds for FY 2025-26

  • Business: audit generally applies where total sales, turnover or gross receipts exceed ₹1 crore.

  • Eligible low-cash business: the business threshold is ₹10 crore where cash receipts do not exceed 5% of aggregate receipts AND cash payments do not exceed 5% of aggregate payments.

  • Profession: gross professional receipts exceeding ₹50 lakh generally trigger tax audit, subject to the statutory framework and presumptive-tax provisions.

  • Presumptive taxation can create separate audit consequences, so a Section 44AD/44ADA review should be done independently where relevant.

The ₹10 crore rule is therefore not a general turnover exemption. It is a conditional threshold that depends on two separate cash-percentage tests.

2. How the 5% cash test actually works

For the enhanced ₹10 crore business threshold, calculate the cash percentage twice: once for receipts and once for payments. Both must be within 5%. If either side exceeds 5%, the ordinary ₹1 crore threshold applies.

For this purpose, the law treats receipts or payments by a cheque or bank draft that is not account payee as cash. Finance teams should therefore not classify every banking instrument as non-cash merely because it passed through a bank.

Example

Assume a trading company has turnover of ₹6.80 crore. Aggregate receipts during the year are ₹7.00 crore, of which ₹21 lakh is cash (3%). Aggregate payments are ₹5.50 crore, of which ₹33 lakh is cash (6%). Even though cash receipts are below 5%, cash payments exceed 5%. The company does not get the ₹10 crore threshold and must test audit applicability under the ordinary ₹1 crore business threshold.

3. What should be included in turnover?

Section 44AB uses the commercial expressions sales, turnover and gross receipts without defining every component. ICAI's tax-audit guidance therefore remains important for practical computation. The core approach is to identify the aggregate amount for which sales are effected or services are rendered, read consistently with the method of accounting and the substance of the business.

Trade discounts and rebates

A trade discount that reduces the sale price can generally reduce turnover. A financing-style cash discount or a commission paid to a third party is different and should not automatically be netted from turnover.

Scrap and incidental business receipts

Scrap or wastage sales connected with the business should not be ignored merely because they appear under 'other income' or 'miscellaneous income'. Likewise, certain business-linked receipts can form part of gross receipts depending on their nature.

Reimbursements

Pure reimbursements require substance-based review. Where expenses and reimbursements are tracked separately, the tax-audit treatment can differ from a simple gross-invoice approach. Keep agreements, invoices and ledger mapping available to support the adopted treatment.

4. Should GST be included in turnover for tax audit?

There is no safe one-line answer for every accounting system. ICAI guidance has historically distinguished between indirect taxes embedded in the sale price and taxes separately credited to a tax liability account. Where GST is separately accounted for as a liability and not credited as revenue, it should not be mechanically added to turnover merely because it appears on the customer invoice. The treatment must be consistent with the books, applicable accounting framework and the turnover policy documented for tax audit.

This is why a turnover reconciliation should bridge revenue as per the financial statements, GST outward-supply data, credit notes, discounts, scrap or incidental sales and the final Section 44AB turnover figure.

5. F&O, derivatives and securities need a different turnover approach

For futures, options and certain speculative transactions, gross contract value is not automatically the Section 44AB turnover. ICAI guidance uses a differences-based approach for derivatives, including favourable and unfavourable differences and specified option-premium/reverse-trade adjustments. A trader with very large notional contract values may therefore have a much smaller tax-audit turnover figure.

Related PGT guide: https://www.pgtandassociates.com/post/fo-tax-audit-ay-2026-27

6. Turnover reconciliation checklist before deciding audit applicability

  • Start with audited or final trial-balance revenue, not only GST turnover or bank credits.

  • Reconcile sales returns, credit notes, trade discounts and year-end cut-off adjustments.

  • Identify scrap, wastage and incidental business receipts recorded outside the sales ledger.

  • Document the GST/indirect-tax accounting policy used in the turnover computation.

  • Separate capital receipts and receipts unrelated to business turnover.

  • For F&O or speculative trades, compute turnover using the appropriate differences-based methodology rather than notional contract value.

  • Compute cash receipts as a percentage of aggregate receipts.

  • Compute cash payments as a percentage of aggregate payments.

  • Treat non-account-payee cheques and drafts as cash for the 5% test.

  • Retain a signed turnover working paper that reconciles the Section 44AB conclusion to the books and return data.

7. Practical example: GST, discounts and scrap

Suppose a manufacturer records ₹4.40 crore of revenue excluding GST, gives ₹8 lakh of invoice-linked trade discounts already netted from revenue, and sells production scrap of ₹12 lakh recorded under other income. If GST is separately accounted for as a liability, the tax-audit turnover analysis should begin with the accounting revenue and then examine whether the ₹12 lakh scrap sale belongs in business turnover. The result should not be derived simply by taking the gross taxable value from one GST report without reconciling the books.

8. Common mistakes that create audit risk

  • Using GSTR-1 turnover as the only Section 44AB turnover figure without a book reconciliation.

  • Applying the ₹10 crore threshold merely because most collections are digital, without separately testing payments.

  • Ignoring non-account-payee cheques while calculating the cash percentage.

  • Using gross F&O contract value instead of the applicable derivatives-turnover methodology.

  • Excluding scrap or other business-linked receipts solely because they are classified below revenue in the P&L.

  • Changing the turnover methodology from year to year without documenting the reason.

FAQs

Is the tax audit threshold ₹1 crore or ₹10 crore for AY 2026-27?

For business, ₹1 crore is the ordinary threshold. ₹10 crore applies only where both cash receipts and cash payments stay within the statutory 5% conditions.

Does UPI, NEFT or RTGS count as cash?

Ordinary electronic bank transfers are not cash. The specific statutory deeming rule targets cheques and bank drafts that are not account payee, which are treated as cash for the 5% test.

Can turnover for GST and income-tax audit differ?

Yes. The reporting systems serve different statutes and can use different concepts, timing and adjustments. Differences should be reconcilable and documented rather than assumed to be errors.

Does every receipt in the bank account form part of turnover?

No. Capital introduced, loans, inter-account transfers and other non-business receipts are not turnover merely because money entered a bank account. Classification depends on the legal and commercial nature of the receipt.

Which tax-audit forms apply for AY 2026-27?

For FY 2025-26 / AY 2026-27, the Income Tax Department confirms continued use of Form 3CA or 3CB together with Form 3CD under the Income-tax Act, 1961.

Related PGT & Associates guides

F&O Tax Audit AY 2026-27: https://www.pgtandassociates.com/post/fo-tax-audit-ay-2026-27

Form 26 Tax Audit from 1 April 2026: https://www.pgtandassociates.com/post/form-26-tax-audit

Primary references

Income Tax Department — Income Tax Forms FAQs: AY 2026–27 tax-audit forms and thresholds. CBDT's 28 September 2026 announcement separately extended the ordinary audit-report deadline to 21 October 2026.

Income Tax Department — Notification No. 47/2026: AY 2026-27 return validation fields testing turnover ranges and the 5% cash receipt/payment conditions.

ICAI — Guidance Note on Tax Audit under Section 44AB (Revised 2026/current professional guidance): practical treatment of sales, turnover, gross receipts and specialised transactions.

Need a Section 44AB applicability review?

PGT & Associates assists businesses and professionals with tax-audit applicability, turnover reconciliation, Form 3CA/3CB/3CD preparation and pre-filing review. For a transaction-specific assessment, contact the firm through https://www.pgtandassociates.com/ before the audit and return-filing deadlines.

Disclaimer: This article is for general professional information and is not legal, tax or accounting advice for any specific transaction. Tax-audit applicability depends on the facts, books, accounting policies, presumptive-tax provisions and law applicable to the taxpayer. Obtain professional advice before acting on the conclusions above.

 
 
 

Comments

Rated 0 out of 5 stars.
No ratings yet

Add a rating
bottom of page