The Institute of Chartered Accountants of India (ICAI) has issued a set of Frequently Asked Questions (FAQs) clarifying the implementation of the ceiling on Tax Audit assignments through the Unique Document Identification Number (UDIN) system. The said ceiling has been notified under the “Chartered Accountants (Limit on Number of Tax Audits) Guidelines, 2025”, as published in the Gazette of India, and shall come into force with effect from April 1, 2026.
As per the FAQs, a ceiling of 60 Tax Audit assignments per financial year per member shall be applicable at the time of UDIN generation under Tax Audit. The ceiling shall be computed on the basis of the date of signing of the Tax Audit Report during the financial year, and not on the date of UDIN generation. Only the specified sub-categories under “GST & Tax Audit” shall be considered for computation of the ceiling.
Applicable sub-categories on which the ceiling shall be applicable include Form 3CA – 3rd proviso to Section 44AB, Form 3CB – Section 44AB(a), Form 3CB – Section 44AB(b), and Form 3CB (Combined) under Section 44AB. The non-applicable sub-categories include Form 3CB – Section 44AB(c), Form 3CB – Section 44AB(d) and Form 3CB – Section 44AB(e).
It has been clarified that the UDIN system shall aggregate all Tax Audit UDINs generated by a member, whether in individual capacity or as a partner in one or more firms, for the purpose of ceiling. Further, UDINs generated for revised Tax Audit Reports shall not be treated as separate assignments for the purpose of ceiling.
In respect of Head Office and Branch audits, audits of Head Office and branches of the same assessee for the same assessment year shall be treated as one Tax Audit assignment. Although separate UDINs may be generated, the ceiling count shall not increase. Similarly, multiple UDINs generated under the applicable sub-categories for the same assessee and same assessment year shall be treated as one assignment, whereas UDINs generated for different assessment years for the same assessee shall be treated as separate assignments.
The FAQs further provide that where UDINs are generated for the same assessee under multiple forms within the applicable sub-categories, no additional count shall be made, provided the audits pertain to the same PAN and same assessment year. In case of change in sub-category from a non-applicable sub-category to an applicable sub-category, the assignment shall be counted towards the ceiling and the available limit shall be reduced. Conversely, on change from an applicable sub-category to a non-applicable sub-category, the assignment shall be excluded from the ceiling and the available limit shall increase accordingly.
The detailed FAQs along with Annexure I containing the “Chartered Accountants (Limit on Number of Tax Audits) Guidelines, 2025” have been made available by the ICAI for the guidance of members.
The FAQs can be accessed at: https://a2ztaxcorp.net/wp-content/uploads/2026/05/ICAI-Issues-FAQs-on-Ceiling-for-UDIN-Generation.pdf
