Last reviewed: 25 September 2026.
When we first published this checklist in February 2026, most of the Budget's provisions were still proposals and the Income-tax Act, 2025 was six weeks from taking effect. Seven months on, the picture has changed: the new Act is in force, deadlines that were "due later this year" have either passed, been extended, or arrived on the calendar. This update replaces the original prospective checklist with a status check — what MSMEs, startups and founders should already have done, what is due in the next few weeks, and where the numbers moved since February.
The deadline status board — what's actually due now
The single most useful thing this update can do is replace "confirm before acting" with an actual position as of 25 September 2026.
| Item | Position in February 2026 | Position as of 25 September 2026 | What to do |
|---|---|---|---|
| ITR due dates, AY 2026-27 | Statutory due date 31 July 2026 | Finance Act 2026 moved the non-audit business due date (ITR-3/4) to 31 August 2026; ITR-1/2 stayed at 31 July 2026. Both have passed; belated returns are open to 31 December 2026 | If not filed, file a belated return without further delay — interest and, ordinarily, a late fee apply |
| MCA CCFS-2026 (ROC amnesty) | Not yet announced | CCFS-2026 closed on 15 September 2026, after two extensions; pending forms now attract full additional fees | File any pending AOC-4/MGT-7/7A-type forms now; the additional fee keeps accruing per form until filed |
| Advance tax, Q2 FY 2026-27 | Not yet due | 15 September 2026 (cumulative 45% of estimated tax liability) has passed; next instalment 15 December 2026 (cumulative 75%) | Recompute estimated income under your chosen regime; interest under Section 425 (old 234C) applies on any shortfall |
| DPIIT startup recognition | Turnover ceiling ₹100 crore | Ceiling doubled to ₹200 crore from 4 Feb 2026 (Notification G.S.R. 108(E)); deep-tech category gets ₹300 crore and a 20-year window | Recheck eligibility if you crossed ₹100 crore and assumed recognition was closed to you |
| Tax audit report, AY 2026-27 (Sec 44AB) | Statutory 30 September 2026 | Still 30 September 2026 — no extension notified as of 25 September 2026 | File Form 3CA/3CB-3CD ahead of the deadline; the return itself follows on 31 October 2026 for audit cases |
| GSTR-9 / 9C, FY 2025-26 | Not yet due | Standard due date 31 December 2026 | Start ITC and turnover reconciliation now rather than in Q4 |
Dates above reflect the standard statutory position and public notifications as understood on the review date; check the live position on the relevant portal before the last week of any window.
For MSMEs: turn 43B(h) into an operating routine, not a year-end scramble
Section 43B(h) (FY 2025-26) / Section 37(2)(g) of the Income-tax Act, 2025 (FY 2026-27) denies the buyer's deduction for any amount payable to a micro or small enterprise supplier that is not actually paid within the period agreed in writing (capped at 45 days) or within 15 days where there is no such agreement. The disallowance applies for the year the expense was booked; the deduction shifts to the year of actual payment. Combined with GST and TDS filings that are now largely automated and cross-checked, the practical discipline for FY 2026-27 is: flag Udyam-registered vendors in your accounting system, track payment ageing against the agreed term (not just the invoice date), and close the loop before the books are finalised — not after the tax auditor asks. Our detailed Section 43B(h) walkthrough covers the agreement-vs-no-agreement distinction and buyer-side risk in full.
Worked example — what the disallowance costs in rupees
| Component | Detail |
|---|---|
| Invoice from a Udyam-registered micro enterprise | ₹6,00,000 |
| Agreed credit period | 45 days |
| Actual date of payment | 62 days after invoice (17 days late) |
| Effect under Section 37(2)(g) (old 43B(h)) | ₹6,00,000 disallowed for FY 2026-27; deductible only in the year of actual payment |
| Approximate tax impact this year (25% corporate rate) | ₹1,50,000 additional current-year tax outflow — a timing cost that reverses next year, but a real cash-tax hit now |
Beyond 43B(h), keep GST returns and ITC reconciliation current: since the July 2025 tax period the liability auto-populated into GSTR-3B from GSTR-1/1A can no longer be edited in the return, and ITC now flows through the Invoice Management System, so mismatches can no longer be smoothed over after filing in the way they once could. Reconciling before the return is filed — not after — is now the only workable sequence. Where eligible, the simplified GST registration route under Rule 14A remains available for small B2B taxpayers who want a faster GSTIN without the full documentation cycle.
For startups: the ground shifted twice since February
Two changes affect startups directly this year. First, the DPIIT turnover ceiling for recognition doubled from ₹100 crore to ₹200 crore with effect from 4 February 2026, and a new deep-tech category carries a ₹300 crore ceiling with a 20-year recognition window instead of the standard 10 years — run your own numbers through our DPIIT Eligibility Checker rather than relying on an older article that still quotes ₹100 crore. If your turnover crossed ₹100 crore and you assumed recognition was closed to you, it is worth rechecking. Second, the angel-tax provision on share premium from resident investors — withdrawn for all investor classes from FY 2024-25 — continues to stay withdrawn under the Income-tax Act, 2025, removing one of the older frictions in closing a domestic round. Valuation discipline for the allotment itself, however, is unchanged: a fair-value backing is still good practice even where the tax trigger has been removed.
Worked example — the startup tax holiday (Section 140 of the 2025 Act, old 80-IAC) in a profitable year
| Particulars | Without the deduction | With the deduction elected for the year |
|---|---|---|
| Profit before tax | ₹80,00,000 | ₹80,00,000 |
| Section 140 of the 2025 Act (old 80-IAC) deduction | Nil | ₹80,00,000 (100% of eligible profit) |
| Taxable income | ₹80,00,000 | Nil, subject to applicable minimum-tax provisions for the year |
| Approximate tax at 25% plus 4% cess (no surcharge below ₹1 crore) | ₹20,80,000 (illustrative) | Nil, or the minimum-tax floor if applicable |
The deduction is available for any 3 consecutive years out of the first 10 years from incorporation, only for an eligible startup incorporated before 1 April 2030, and only after DPIIT recognition and a separate certification from the Inter-Ministerial Board are both in place — it is not automatic on recognition alone. Confirm minimum-tax applicability for the specific year before relying on the full saving in a cash-flow projection. Alongside this, keep the cap table and ESOP documentation current for diligence, and stay on top of FEMA filings — the annual FLA return and event-based FC-GPR filing on any foreign allotment — since a lapse here is one of the more common issues that surfaces during a funding round, well after the original deadline has passed.
For founders: the regime choice and the advance-tax clock
The Section 87A rebate structure for AY 2026-27, including the ₹12 lakh effective nil-tax point under the new regime, changes the regime-choice arithmetic for a founder with a mix of salary, dividend and capital-gains income — see our dedicated Section 87A rebate review for the mechanics, or run both regimes through our Income Tax Calculator directly. What that review does not replace is the advance-tax obligation on non-salary income, which does not wait for the annual return.
Use our Advance Tax Calculator to work out your own instalment before the next due date rather than the illustrative figures below.
Worked example — advance tax and the cost of underpaying by 15 September
| Instalment | Due date | Cumulative % required | If only 30% is paid by 15 Sep |
|---|---|---|---|
| First | 15 June | 15% | — |
| Second | 15 September | 45% | Shortfall of 15 percentage points against the cumulative requirement |
| Third | 15 December | 75% | Interest under Section 425 (old 234C) of 1% per month runs on the shortfall for the second instalment regardless of catch-up later |
| Fourth | 15 March | 100% | Full and final reconciliation; balance tax, if any, carries interest under Section 424 (old 234B) from 1 April |
Founders should also use this window to report capital gains from any share transfer, ESOP exercise or property sale in the year, disclose all income including exempt income, and confirm foreign-asset disclosure (Schedule FA) where ESOPs or investments are held abroad — a disclosure obligation that applies regardless of whether any tax is actually payable on the underlying asset.
ROC compliance: the CCFS-2026 window closed on 15 September 2026
The Companies Compliance Facilitation Scheme, 2026 let companies clear a backlog of pending annual filings — AOC-4 and MGT-7/7A among them — at a sharply reduced additional fee instead of the full late-filing penalty that otherwise accrues per form, per year of delay. The scheme's closing date moved twice, first to 31 August 2026 and then to 15 September 2026, and the window closed on that date. Pending forms now attract the full additional fee, which keeps accruing until the form is filed, so companies still sitting on one or two years of pending filings should check their MCA master data and file without waiting for another scheme. See our dedicated CCFS-2026 filing guide for the form-by-form detail.
We convert the Budget, the new Act and every extension since into a dated action plan for your business — and help you plan and clear ROC and tax backlogs.
CCFS-2026 ROC Filing Virtual CFO Income Tax FilingFrequently asked questions
What actually changed since this checklist was first published in February 2026?
Three things moved in practice: the Income-tax Act, 2025 came into force from 1 April 2026 and is now the working law rather than a future event; the Finance Act 2026 moved the AY 2026-27 due date for non-audit business returns (ITR-3/ITR-4) to 31 August 2026, while ITR-1/ITR-2 stayed at 31 July 2026, and both dates have now passed; and the DPIIT startup turnover ceiling was doubled from ₹100 crore to ₹200 crore with effect from 4 February 2026. Anything you read from before these dates should be re-checked.
Is the CCFS-2026 ROC amnesty window still open?
No. The Companies Compliance Facilitation Scheme, 2026 closed on 15 September 2026, after MCA had extended it twice (first to 31 August 2026, then to 15 September 2026). Annual-filing forms such as AOC-4 and MGT-7/7A that are still pending now attract the full additional fee under the normal late-filing rules.
Has the DPIIT startup turnover ceiling really doubled?
Yes. Notification G.S.R. 108(E) dated 4 February 2026 superseded the 2019 recognition framework: the standard turnover ceiling for DPIIT recognition rose from ₹100 crore to ₹200 crore (checked across any financial year since incorporation), and a new deep-tech category got a ₹300 crore ceiling with a 20-year recognition window instead of the usual 10 years.
What happens if I missed the 31 August 2026 ITR due date?
A return filed after the due date is a belated return under Section 139(4), which for AY 2026-27 can be filed up to 31 December 2026. It carries interest on any unpaid tax and, ordinarily, a late fee. Certain carry-forward benefits for losses (other than house-property loss) are also lost. File it at the earliest — a belated return is still far better than not filing at all.
How much advance tax should a founder have paid by 15 September 2026?
The standard schedule requires 45% of the year's estimated tax liability to be paid, cumulatively, by the second instalment on 15 September (after 15% by 15 June). For FY 2026-27, a shortfall against this cumulative percentage attracts interest under Section 425 of the Income-tax Act, 2025 (old Section 234C), calculated instalment-wise, even if the full year's tax is eventually paid on time.
Is angel tax really abolished under the Income-tax Act, 2025?
The angel-tax provision — taxing share premium received from resident investors as income — was withdrawn for all classes of investors from FY 2024-25 onward, and that relief continues under the Income-tax Act, 2025. It removes one of the older frictions in raising a domestic funding round, though valuation and FEMA compliance on the same allotment still apply.
What does the Section 43B(h) disallowance actually cost an MSME buyer in practice?
If payment to a micro or small enterprise supplier is not made within the agreed period (capped at 45 days) or 15 days where there is no agreement, the expense is disallowed for that year and can only be claimed as a deduction in the year the payment is actually made. The rule is Section 43B(h) for FY 2025-26 and Section 37(2)(g) of the Income-tax Act, 2025 for FY 2026-27. It is a timing cost, not a permanent loss of deduction — but it still increases the current year's taxable income and cash tax outflow.
Where can I check my own compliance dates for the rest of FY 2026-27?
Use our free Compliance Calendar tool to build a date list specific to your entity type — income tax, GST, TDS, ROC and FEMA dates in one place — rather than relying on a generic list that may already be out of date by the time you read it.
Talk to CA Somesh Chandak & Associates — we turn Budget changes and every extension since into action for your business.
WhatsApp LinkedIn Schedule a callBuild your own Compliance Calendar for the rest of FY 2026-27 rather than relying on a generic list that can go stale within weeks, as this one did.
Disclaimer: This article is for general guidance only and reflects the position understood as on 25 September 2026. The DPIIT turnover ceiling, statutory due dates and Budget-linked thresholds have each already changed at least once this year and can change again; please confirm the current position with us or on the relevant government portal before acting, particularly close to any deadline mentioned above.