MIS Reconciliation before Due Diligence: A Complete Guide

MIS reconciliation before due diligence is the work of proving that every number you have already shown investors (revenue, margins, EBITDA, burn, ARR, cash) ties back to your books, your audited financials, your statutory filings and your bank. In India, an investor’s financial due diligence team can independently pull month-wise revenue from GST returns, receipts from the Annual Information Statement and payroll from TDS and provident fund filings, so your MIS will be tested against sources you cannot edit. Differences you explain upfront read as housekeeping. Differences they find read as a credibility problem, and usually come back as price adjustments, escrows or specific indemnities. This guide covers the reconciliation stack, materiality, a step-by-step process, self-testing, the tax exposure layer and what to do when a number will not reconcile.

What is MIS reconciliation before due diligence?

MIS reconciliation before due diligence is a documented bridge between management-reported numbers and the company’s books of account, audited financials, GST and TDS filings and bank statements, prepared before the data room opens. Every difference is listed as a named reconciling item with an amount, a reason and evidence. The output is a reconciliation pack that lets an investor verify your numbers instead of rebuilding them.

Why MIS and books never match on their own

MIS and books diverge because they serve different purposes. MIS is produced quickly, on management definitions, often from operational systems such as a payment gateway, a billing tool or a CRM. Books follow Section 128 of the Companies Act 2013 and the applicable accounting framework (Ind AS or the Companies (Accounting Standards) Rules). Every company has differences between the two; diligence tests whether you can explain each one.

The recurring causes in Indian startups:

• Timing: MIS closes early in the month; books later pick up accruals, provisions and year-end audit adjustments that never flow back into the MIS already sent.
• Definitions: MIS revenue may be GMV, gross of GST, gross of refunds or bookings rather than recognised revenue.
• Source systems: MIS pulled from operational tools captures orders or bookings; books capture invoices. Failed payments, chargebacks and settlement lags sit between them.
• Classification: A cost sits in marketing in MIS and in employee benefit expense in books, which moves contribution margin without changing EBITDA.
• Entity scope: MIS shows the group or the India business only, while statutory accounts are standalone, or the reverse.
• Restatements: Prior-year audited numbers were restated, but MIS sent to investors for that period was never revised.

If the books themselves are not in order, fix that first; books reconstruction before statutory audit covers that work. This guide assumes the books are closed and audited and the task is to bridge to them.

The reconciliation stack: MIS vs audited financials, filings and bank

A complete reconciliation ties MIS to five layers, each of which a diligence team can access independently. A number that survives all five is defensible.

Table 1: The five layers of MIS reconciliation and what each tests

Layer	Source the investor checks	What it proves	Typical reconciling items
Books of account	Trial balance, general ledger, audit trail log	MIS numbers exist in the ledger	Accruals, provisions, reclassifications, cut-off
Audited financials	Signed financial statements, notes, audit report, CARO 2020 report	Ledger matches what the auditor signed	Audit adjustments, restatements, Ind AS adjustments
GST returns	GSTR-1, GSTR-3B, GSTR-2B, GSTR-9/9C	Revenue and purchases match tax reporting	Credit notes, advances, exports, ITC timing
Income tax and payroll filings	Form 26AS / AIS, TDS returns, PF and ESI challans	Receipts, salaries and vendor payments match authority data	Customer TDS, salary TDS, headcount and PF mismatches
Bank	Bank statements, gateway settlement reports, confirmations	Revenue became cash; the cash balance is real	Settlement lags, refunds, chargebacks, gateway fees

Two regulatory points shape this stack in 2026. First, the Income-tax Act 2025 replaced the Income-tax Act 1961 from 01/04/2026. TDS on salary now sits in Section 392 and non-salary TDS in Section 393; where the earlier of credit or payment falls on or before 31/03/2026, the 1961 Act provisions (Sections 192 to 194T) still govern. A diligence period of FY 2024-25 to tax year 2026-27 therefore spans both Acts. Second, input tax credit is available only where the supplier’s invoice appears in GSTR-2B under Section 16(2)(aa) of the CGST Act 2017, so any ITC gap between books and GSTR-2B is a quantifiable exposure.

Which layer do investors test first?

Most Indian financial due diligence teams start with GST, because GSTR-1 and GSTR-3B give an independent, month-wise revenue figure the company cannot change after filing. If MIS revenue for a month is materially higher than GSTR-1 taxable value without a stated reason, every other number in the MIS gets tested harder.

Does the audit trail rule matter for reconciliation?

Yes. Rule 3(1) of the Companies (Accounts) Rules 2014, applicable from 01/04/2023, requires accounting software with an audit trail that cannot be disabled, and auditors report on it. A diligence team can ask for the edit log. Entries posted or changed after the MIS was sent, or after the audit was signed, need to appear as reconciling items, not as silent corrections.

Setting materiality and scope before you start

Materiality decides which differences you investigate line by line and which you aggregate. Without it, teams either chase ₹500 differences for weeks or wave through a ₹40 lakh gap as “timing”.

A practical approach used in diligence preparation (market practice rather than a regulatory threshold, agreed with your VCFO or auditor):

• Set a quantitative threshold: typically a small percentage of revenue or EBITDA, whichever gives the lower figure, applied per line per month.
• Treat some items as always material: anything touching tax exposure, related parties, founder payments, cash or revenue recognition policy, regardless of size.
• Aggregate the rest: differences below threshold are grouped as “other” with a total, and the total itself must be below threshold.
• Fix the period: the same period the investor will test, usually two audited years plus current year-to-date. Confirm it from the investor’s diligence scope letter or information request list.
• Fix the entity perimeter: standalone, consolidated, or both, matching what the investor is buying into.

How to do MIS reconciliation before due diligence: step-by-step process

Work top-down: P&L first, then balance sheet, then tax filings, then metrics.

1. Freeze the MIS versions. Collect every MIS pack, board deck and investor update sent in the review period. The versions investors received are the ones that must reconcile, not a tidied version.
2. Map the chart of accounts. Build a mapping table from every ledger head to the MIS line it rolls into. Most classification differences surface here, before any numbers are compared.
3. Revenue bridge (monthly). MIS revenue, less GST, less refunds and credit notes, less principal versus agent adjustment, plus or minus cut-off and deferral, equals book revenue. Then book revenue to GSTR-1 taxable value.
4. Cost and margin bridge. Tie gross and contribution margin at the MIS definition to the ledger, and document allocation keys (for example, how cloud cost is split between cost of revenue and R&D).
5. EBITDA bridge. Reported MIS EBITDA to book EBITDA, then book EBITDA to any adjusted EBITDA you have quoted (covered in the next section).
6. Burn and cash bridge. MIS burn to the movement in bank and liquid investments, separating operating burn from capex, debt and equity flows.
7. Balance sheet tie-outs. Debtors and creditors ageing to ledger, cash to bank confirmations, deferred revenue to contract schedules, statutory dues to the portals, provisions to their working.
8. Tax and payroll portal tie-outs. Books to GSTR-1, GSTR-3B and GSTR-2B; books to Form 26AS / AIS and TDS returns; payroll to PF and ESI challans.
9. Self-test. Run the sample tests a diligence team will run (covered below).
10. Write the reconciling items memo and disclosure note. One line per item: amount, period, reason, evidence reference, one-off or recurring, fixed or disclosed.

If the investor will also test projections, run financial model validation before a data room in parallel so the model’s opening balances tie to the reconciled actuals.

How long does MIS reconciliation take?

For a single entity with clean monthly closes, reconciling 24 to 30 months usually takes 3 to 4 weeks. Multi-entity groups, marketplaces with heavy refund flows, or companies that switched accounting software mid-period typically need 6 to 8 weeks. Starting 30 to 90 days before diligence is the practical window; starting after the term sheet means the exclusivity clock is running against you.

Table 2: Indicative reconciliation timeline (based on Treelife engagements)

Week	Workstream	Output	Owner
1	MIS freeze, materiality, chart of accounts mapping	Mapping table, MIS inventory, materiality note	Finance lead + VCFO
2	Revenue, margin and EBITDA bridges	Monthly P&L bridge schedules	VCFO
3	Balance sheet, tax and payroll tie-outs	GST, TDS, PF and bank reconciliations	VCFO + tax team
4	Self-testing, metric ties, reconciling items memo	Sample test results, memo, disclosure note	Founder + VCFO
5 to 6 (if needed)	Fixes: return amendments, rectification, restated MIS	Corrected filings, restatement bridge	Tax team + founder

Revenue bridge: MIS to books to GSTR-1

Revenue is where most breaks sit, because MIS revenue is usually defined commercially while book revenue follows the accounting standard. The bridge does not re-argue recognition policy; it shows, month by month, how the commercial number becomes the accounting number and then the tax number. For the recognition rules themselves (performance obligations, onboarding fees, upgrades mid-contract), see our guide on Ind AS 115 revenue recognition for SaaS and subscription businesses.

The bridge lines that appear in almost every Indian revenue reconciliation:

• GST: MIS figures pulled from payment data are often tax-inclusive.
• Principal versus agent: marketplaces, aggregators and D2C brands selling through quick commerce often report GMV; books record only the commission or margin where the company acts as agent under Ind AS 115.
• Deferral: annual prepaid contracts billed upfront appear in full in bookings-based MIS but are recognised over the contract term.
• Refunds, returns and credit notes: booked in a later month in the ledger than in the operational system.
• Unbilled revenue and cut-off: services delivered but not invoiced at month-end.

From book revenue to GSTR-1, acceptable differences include advances received for services (taxable on receipt), credit notes issued in later periods, exports and SEZ supplies reported separately, and unbilled revenue. An invoice booked but never reported in GSTR-1 is not a reconciling item; it is a tax exposure.

What will the diligence team do with my revenue bridge?

They will test it rather than accept it. Expect them to trace a sample of transactions from contract to invoice to GSTR-1 to bank receipt, to check whether multi-year contracts are double-counted in ARR, and to compare month-end revenue spikes against credit notes issued in the following month. Running these tests yourself first is covered in the self-testing section below.

EBITDA bridge for due diligence: reported, book and adjusted

The EBITDA bridge is the schedule that most directly affects price, because valuation multiples are often applied to it. It has three levels, and investors want to see each one separately.

Table 3: The three-level EBITDA bridge

Level	What it is	Typical bridge items	What diligence tests
MIS EBITDA	The figure in board decks and investor updates	Classification, cut-off, missing accruals	Whether it was ever true as reported
Book EBITDA	EBITDA derived from audited or closed books	Audit adjustments, provisions, Ind AS entries	Tie to signed financials
Adjusted EBITDA	Book EBITDA after normalisation	ESOP expense (Ind AS 102), one-off legal or restructuring costs, founder-related costs	Whether each add-back is evidenced and genuinely non-recurring
Run-rate EBITDA	Adjusted EBITDA annualised or pro forma	New contracts, price changes, cost cuts already made	Whether the assumption has happened, not just been planned

Two rules keep this bridge credible. First, every add-back needs a document: an invoice, a board resolution, a settlement agreement. Second, add-backs must be symmetrical; if you remove a one-off cost, remove one-off income too. Share-based payment expense under Ind AS 102 is the most common add-back; our note on ESOP expense under Ind AS 102 explains how it is measured. How investors then convert adjusted EBITDA, net debt and working capital into price is covered in our page on financial due diligence services in India.

Balance sheet tie-outs and the items that become debt

Balance sheet reconciliation matters in diligence because unreconciled liabilities tend to be treated as debt-like items and deducted from the equity value. A P&L gap moves the multiple; a balance sheet gap moves the cheque.

Balances to tie, and why each matters:

• Cash and bank: every account (including dormant ones and gateway nodal balances) to bank statements or confirmations as at the period end.
• Gateway clearing or suspense accounts: broken down settlement by settlement. An unexplained balance here is treated as unverified revenue.
• Debtors: ageing to ledger, with customer TDS receivable separated and tied to Form 26AS / AIS.
• Creditors: ageing to ledger, with MSME vendors tagged (see the tax layer below).
• Deferred revenue and customer advances: to the contract schedule. These are usually discussed as debt-like in pricing.
• Statutory dues: GST, TDS, PF, ESI and professional tax payable to the respective portals, with any overdue amount and interest computed.
• Employee provisions: gratuity and leave encashment to the actuarial valuation (Ind AS 19, or AS 15 where Ind AS does not apply). An unprovided gratuity liability is a classic debt-like item.
• Related party balances: to confirmations from the related party and to the related party note in the audited financials.

Payroll and headcount reconciliation

Payroll is usually the largest cost line, and diligence teams reconcile it from three directions: the payroll register, the ledger and the statutory filings. Headcount figures in the MIS or pitch deck are tested the same way.

Tie the following for each month in the review period:

1. Payroll register gross salary to employee benefit expense in the ledger.
2. Salary TDS deducted to the quarterly salary TDS return (Section 192 of the 1961 Act for periods to 31/03/2026, Section 392 of the 2025 Act thereafter).
3. PF and ESI wages and contributions to the challans and electronic challan-cum-returns.
4. MIS headcount to the payroll register, separating employees, interns and consultants.

Consultants paid as vendors while working as full-time staff show up here as a gap between MIS headcount and payroll headcount. Diligence will flag it as a potential PF, gratuity and TDS classification exposure, so decide before the data room opens whether to regularise or disclose.

Multi-entity groups: subsidiaries, intercompany and foreign currency

Groups with a foreign holding company, an Indian subsidiary or overseas sales entities need one more bridge: from the entity-level books to the group view shown in MIS.

The items that drive most group reconciliation differences:

• Intercompany eliminations: services, cost recharges and loans between entities must eliminate to zero. Mismatched intercompany balances are among the first things a diligence team flags.
• Foreign currency translation: MIS often converts at a single budget rate; books use transaction-date and period-end rates. Show the rate difference as its own bridge line.
• Transfer pricing: intercompany charges in MIS should match the transfer pricing documentation and any Form 3CEB filed. If they differ, it is a tax exposure, not a presentation point; our note on transfer pricing audit triggers covers what draws scrutiny.
• FEMA reporting: foreign investment in the Indian entity and overseas investment by it should tie to filings made through the AD bank under FEMA 1999. These are usually handled in the legal track, but the amounts must agree with the balance sheet.

GST and TDS reconciliation for due diligence: the exposure layer

The tax reconciliation is where gaps turn into money. A presentation difference costs credibility; an unreconciled GST or TDS gap costs an indemnity, an escrow or a price cut.

Table 4: Common tax reconciliation gaps and how investors treat them

Gap	Provision	How diligence treats it	Cheaper fix before DD
ITC in books exceeds GSTR-2B	Section 16(2)(aa), CGST Act 2017	Reversal with interest; specific indemnity	Vendor follow-up, reverse in next GSTR-3B, disclose
Invoices missing from GSTR-1	Sections 37 and 39, CGST Act 2017	Tax plus interest under Section 50; indemnity	Report in the next return, pay interest
Customer TDS not in Form 26AS / AIS	Customer-side TDS reporting	Receivable written down	Chase customers to file or revise TDS returns
Vendor TDS short-deducted	Sections 192 to 194T, Income-tax Act 1961 (to 31/03/2026); Sections 392 and 393, Income-tax Act 2025 (from 01/04/2026)	Disallowance risk plus interest	Pay shortfall with interest, file correction statement
MSME vendor dues beyond the agreed or statutory period at year-end	Section 43B(h), Income-tax Act 1961 (from FY 2023-24)	Expense disallowed until paid	Clear dues before year-end; tag MSME vendors in the ledger

Two timing points make early reconciliation cheaper. First, the Finance Act 2023 inserted time limits in Sections 37(5), 39(11) and 44(2) of the CGST Act 2017, barring filing of GSTR-1, GSTR-3B and the annual return after three years from the due date (operative from the July 2025 tax period). Old-period gaps found late may no longer be fixable through returns, only through payment and disclosure. Second, the GST Invoice Management System, live since 01/10/2024, lets you accept, reject or keep pending supplier invoices before they reach GSTR-2B, which makes monthly ITC reconciliation materially easier than a year-end exercise.

Self-testing: run the diligence team’s tests before they do

A reconciliation proves that totals agree. Self-testing proves that the transactions underneath are real. Diligence teams in India routinely run the tests below, and each takes a few days to run internally.

Table 5: Self-tests to run before the data room opens

Test	How to run it	What a failure signals
Revenue vouching	Pick 20 to 30 invoices across months and customers; trace contract to invoice to GSTR-1 to bank receipt	Revenue without cash, or cash without a contract
Customer concentration tie	Top 10 customers in MIS to ledger, GSTR-1 and receipts	Concentration understated in the deck
ARR double-count check	List multi-year and upsell contracts; confirm each is counted once in ARR	Inflated ARR
Cut-off test	Review invoices and credit notes 10 days either side of each year-end	Revenue pulled forward
Post-close entries	Review the audit trail for entries dated before but posted after each MIS or audit date	Silent restatements
Expense completeness	Compare vendor statements for the top 15 vendors to creditors ledger	Unrecorded liabilities

For metrics such as ARR, NRR, CAC and cohort revenue, the test is whether each ties to a ledger number, not whether the definition is market-standard. Definitions and benchmarks are covered in our guide on SaaS metrics investors track. For reconciliation, the most common failure is a cohort table built from the product database whose monthly totals do not equal recognised revenue for the same month.

What to do when a number will not reconcile

Some differences cannot be closed: an old gateway balance with no settlement data, an ITC gap from a vendor who has stopped trading, a historical MIS figure that was simply wrong. The choice is between fixing, restating and disclosing.

• Fix when a filing route still exists and the cost is known: amend a return, pay interest, rectify a TDS statement.
• Restate when MIS already sent was materially wrong. Keep the original, show the restated figure, bridge the two and explain the cause. Never overwrite history silently.
• Disclose when the item cannot be fixed before closing. A written disclosure against the warranties limits the claim the investor can later make, and investors generally price a disclosed, quantified item more gently than one they discover. How disclosures interact with warranties and escrows is covered in our notes on representations and warranties in investment agreements and escrow arrangements in share deals.

What goes into the reconciliation pack for the data room?

The pack should be self-explanatory, because every unclear schedule becomes a written query.

1. MIS inventory: every pack sent in the review period, with dates and recipients.
2. Materiality and scope note.
3. Chart of accounts mapping table.
4. Monthly revenue bridge: MIS to books to GSTR-1.
5. Three-level EBITDA bridge with evidence for each add-back.
6. Burn and cash bridge.
7. Balance sheet tie-outs, including statutory dues and employee provisions.
8. Tax and payroll portal reconciliations.
9. Self-test results.
10. Reconciling items memo and disclosure note.

Common mistakes that cost founders time and valuation

Mistake 1: Reconciling a cleaned-up MIS instead of the one investors received. Founders want a tidy starting point, but the diligence team compares against the board decks and updates actually sent. Reconcile the sent versions and bridge any changes.

Mistake 2: Restating historical MIS without a bridge. Replacing old MIS with numbers that match the books looks like concealment, and the audit trail will show when entries changed. Keep the original and bridge it.

Mistake 3: Treating GST reconciliation as annual. Relying on GSTR-9 and GSTR-9C means ITC gaps compound, interest under Section 50 of the CGST Act 2017 accrues, and the three-year filing bar may close the fix route entirely. Reconcile GSTR-2B to books monthly.

Mistake 4: Unsupported add-backs in adjusted EBITDA. “One-off” costs that recur every year, or add-backs without documents, are reversed by the diligence team and damage the credibility of the entire bridge.

Mistake 5: Ignoring the balance sheet. Founders focus on the P&L because that is what the deck shows. Unreconciled clearing accounts, unprovided gratuity and overdue statutory dues come back as debt-like deductions from the equity value.

Treelife practitioner note

In the MIS reconciliation engagements we have run at Treelife, the revenue bridge is rarely where the time goes. Most finance teams can explain gross versus net and know their deferred revenue. The weeks are lost lower down, in balances nobody looked at until a diligence team asked.

The first is the payment gateway clearing account. Gateways settle net of fees, refunds and chargebacks, often across month-ends, so revenue is booked from orders and cash from settlements, and the difference sits in a clearing account. A good month-end close clears this every month, but companies that did not have one for their first two or three years carry historic balances nobody can break down. We have seen these equal 4 to 6% of annual revenue. A diligence team treats an unexplained clearing balance as unverified revenue.

The second is the GSTR-2B gap. Since Section 16(2)(aa) of the CGST Act 2017 made ITC conditional on the supplier’s reporting, every vendor who files late or misreports creates a credit that is booked but not defensible. In logistics, D2C and marketplace businesses with hundreds of vendors, the gap is almost never zero. With the three-year filing bar now operative, the older the gap, the fewer options remain.

The third is the transition between the two Income-tax Acts. Diligence periods now straddle 31/03/2026, and TDS working papers that quote 1961 Act sections for April 2026 payments, or 2025 Act sections for March payments, generate queries that take longer to answer than the underlying issue deserves.

Conclusion

MIS reconciliation before due diligence is not an accounting clean-up. It decides whether your investor spends diligence verifying your numbers or rebuilding them, and whether gaps reach the term sheet as disclosures or as escrows. Start from the MIS as sent, set materiality, bridge to books, audited financials, GST, TDS, payroll and bank, test the transactions the way a diligence team will, and fix, restate or disclose every difference you find. Done 30 to 90 days before the data room opens, it protects both your valuation and your closing timeline.

FAQs on MIS reconciliation before due diligence

Q: Does MIS need to match audited financials exactly?

A: No, but every difference must be explained. Investors expect timing, definition and classification differences; they test whether each is named, quantified and evidenced in a bridge schedule.

Q: How long does MIS reconciliation before due diligence take?

A: Typically 3 to 4 weeks for a single entity with clean monthly closes. Multi-entity groups or businesses with heavy refund flows usually need 6 to 8 weeks.

Q: Who should own the reconciliation, the finance team or an outside advisor?

A: The finance team prepares the data; an independent reviewer should own the bridge. A VCFO or external team that did not prepare the original MIS is more likely to spot the gaps a diligence team will find.

Q: Which documents are needed to start?

A: All MIS packs and investor updates sent, monthly trial balances, audited financials, GSTR-1, GSTR-3B, GSTR-2B and GSTR-9/9C, Form 26AS / AIS, TDS returns, PF and ESI challans, payroll registers, and bank and gateway settlement statements.

Q: How should GMV be presented if MIS has always shown it as revenue?

A: Keep GMV as a disclosed operating metric and bridge it to net revenue. Where the company acts as agent under Ind AS 115, only the commission or margin is revenue, and the diligence team will re-cut multiples quoted on GMV.

Q: Which TDS sections apply to a diligence period that crosses April 2026?

A: Both Acts. Where the earlier of credit or payment falls on or before 31/03/2026, the Income-tax Act 1961 (Sections 192 to 194T) applies; from 01/04/2026, Sections 392 and 393 of the Income-tax Act 2025 apply.

Q: What happens if we find a GST gap during reconciliation?

A: Fix it if a route exists, otherwise disclose it. Reverse unsupported ITC or report missed invoices with interest under Section 50 of the CGST Act 2017; where the three-year filing bar has closed the return route, pay and disclose.

Q: Are there FEMA points in MIS reconciliation?

A: Yes, where foreign currency flows exist. Export receivables should tie to bank realisation, and foreign investment in the balance sheet should tie to filings made through the AD bank under FEMA 1999.

Q: How are founder or co-founder related payments handled?

A: Tag them separately in the mapping table and tie them to Section 188 approvals and the related party note. Our note on related party transactions in financial due diligence covers what investors look for.

Q: Is reconciliation different for a DPIIT-recognised startup?

A: No. DPIIT recognition does not relax GST, TDS or accounting standard requirements, so the reconciliation layers are the same.

Q: What if the round falls through after reconciliation?

A: The work is not wasted. A reconciled pack shortens the next investor’s diligence, supports the statutory audit and surfaces tax gaps that would have accrued interest anyway.

Q: What does an investor do if no reconciliation is provided?

A: They build it themselves, take longer and price the uncertainty. Common outcomes are larger EBITDA adjustments, debt-like deductions, escrows or specific indemnities.

Q: Should historic MIS errors be restated or just disclosed?

A: Restate if the MIS was materially wrong, and always bridge the original to the restated figure. Silent overwrites are visible in the audit trail required under Rule 3(1) of the Companies (Accounts) Rules 2014.

Q: How does reconciliation change for an acquisition rather than a fundraise?

A: The layers are the same, but the balance sheet matters more. In an acquisition, working capital and debt-like items from the tie-outs feed directly into the purchase price adjustment.

Regulatory references

• Companies Act 2013, Section 128 (books of account) and Section 188 (related party transactions)
• Companies (Accounts) Rules 2014, Rule 3(1) (audit trail, from 01/04/2023)
• Companies (Auditor’s Report) Order 2020
• Ind AS 115 (revenue), Ind AS 102 (share-based payment), Ind AS 19 (employee benefits); AS 15 (employee benefits) for non-Ind AS companies
• Central Goods and Services Tax Act 2017, Sections 16(2)(aa), 37, 37(5), 39, 39(11), 44(2) and 50 (time-limit provisions inserted by Finance Act 2023)