VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.44AA(2): who must keep books of account, and the thresholds
CBDT Circulars & InstructionsCuts both waysValidity unconfirmeds.44AAs.271As.44ADs.44AEs.44AB

Statutory position — s.44AA(2): who must keep books of account, and the thresholds

My client runs a small business, not a notified profession. At what point is he obliged to keep books at all, and what are the current figures?

My client runs a small business, not a notified profession. At what point is he obliged to keep books at all, and what are the current figures?

For a business or a non-specified profession, books must be kept if income from the business or profession exceeds Rs 1,20,000 OR total sales, turnover or gross receipts exceed Rs 10,00,000 in any one of the three years immediately preceding the previous year. For an individual or a Hindu undivided family two provisos raise those figures to Rs 2,50,000 and Rs 25,00,000 respectively.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text as published by the Income Tax Department) on 2018-04-01, reported as Income-tax Act 1961, s.44AA, sub-sections (1) to (4), as published on the Income Tax Department's section page for s.44AA. It bears on section 44AA, section 271A, section 44AD, section 44AE, section 44AB of the Income Tax Act 1961, in Presumptive Taxation & Audit and How Tax Law Is Read matters.

Validity check could not be completed. Validity check could not be completed in the sense that no decision construing s.44AA(2) was retrieved on this pass, and none is cited here. The text is the Income Tax Department's own published section page, read on 7 September 2026, and it IS corroborated: a second departmental page, incometaxindia.gov.in/w/section-44aa-48, carries clauses (i) to (iv) and both provisos word for word, and CBDT Circular No. 2/2018 (Explanatory Notes to the Finance Act 2017), paragraph 22, records the two raised figures. The commencement is therefore established and not left open: the two provisos were inserted by the Finance Act 2017 with effect from 1 April 2018, that is from assessment year 2018-19. The only other rendering reached, indiankanoon doc 1376249, is demonstrably out of date — it omits both provisos entirely and carries pre-2016 wording in clauses (iii) and (iv) — and is recorded here only as a warning that indiankanoon's bare-act pages for this section cannot be relied on. A practitioner advising for an assessment year before 2018-19 must use the pre-amendment figures of Rs 1,20,000 and Rs 10,00,000 for every assessee.

Why it matters

This is the provision behind the s.271A penalty, and it is the provision on which the whole s.271A/s.271B argument turns — a s.271B penalty cannot stand where there were no books to audit, and whether there ought to have been books at all is answered here. Three features are easy to get wrong. First, the two tests in clause (i) are alternatives joined by 'or', so a loss-making business with turnover above the limit is still obliged to keep books. Second, the look-back is to any ONE of the three years immediately preceding the previous year, not to the previous year itself — a business that has fallen away this year may still be caught by a good year two years back. Third, the higher figures are not general: they apply only to an individual or a Hindu undivided family, so a firm, an AOP or a company stays at Rs 1,20,000 and Rs 10,00,000. Clauses (iii) and (iv) then bring in the presumptive cases independently of any monetary test: a person who claims income lower than the deemed profits under s.44AE, s.44BB or s.44BBB, and a person to whom s.44AD(4) applies whose income exceeds the maximum amount not chargeable to tax, must keep books whatever their turnover.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

Not yet CA-verified. This entry was found through the sources listed under the Sources tab, and the summary reflects what those sources say. Nobody has yet read the full judgment and signed it off. Check the source before relying on it.

Read aloud by your device. Press again to stop.

Related

Other authorities on the same sections.