ICAI has released ‘Implementation Guide’ for ‘Revised Tax audit Report (Form 3CD)’ applicable from 20/08/2018. This guide will supplement the ICAI’s ‘Guidance Note on Tax Audit (2014)’ and provide clause-wise analysis of amendments in reporting requirements of Form 3CD notified by CBDT, for guidance of Members/ Taxpayers.
It may however be noted that CBDT has subsequently deferred the implementation of Clauses 30C (GAAR) and 44 (GST) of the revised Form 3CD upto 31/03/2022, based on representations received from stakeholders, like ICAI, etc.
ICAI’s ‘Implementation Guide’ for ‘Revised Form 3CD’ Applicable from 20/08/2018
ICAI has last revised the ‘Guidance Note on Tax Audit u/s 44AB‘ in the year 2014. Therefore, the ICAI has released this ‘Implementation Guide’ to support the Members to carry out ‘Tax Audits’ from 20/08/2018 using the revised Form 3CD.
This guide deals with the amendments made by CBDT vide Notification No. 33/2018 dt. 20/07/2018 only, which are applicable from 20/08/2018. Therefore, it is advisable that the existing ‘Guidance Note of ICAI on Tax Audit under section 44AB’ of the Income-tax Act, 1961 (last revised in 2014) is referred to in respect of the clause where there is no new change/ insertion is notified by CBDT. However, for amendments in Form 3CD applicable from 20/08/2018, this Implementation Guide of ICAI needs to be referred to.
Gist of Amendments in Form No. 3CD covered by ICAI’s Implementation Guide
| Sl. No. | Revised/ New Clause in Form 3CD | Page No. |
| 1 | Clause 4 – Liability to GST and Furnishing of GST Number | 3 |
| 2 | Clause 19 – Amounts Admissible under Section 32AD | 4 |
| 3 | Clause 24 – Amounts deemed to be Profits and Gains under section 32AD | 8 |
| 4 | Clause 26 – Sums referred to in section 43B | 9 |
| 5 | Clause 29A – Amount Chargeable under section 56(2)(ix) | 11 |
| 6 | Clause 29B – Income chargeable under section 56(2)(x) | 14 |
| 7 | Clause 30A – Secondary Transfer Pricing Adjustments | 20 |
| 8 | Clause 30B – Limitation on Interest Deduction | 26 |
| 9 | Clauses 31(ba), (bb), (bc) and (bd) | 30 |
| 10 | Clauses 31(c), (d) and (e) | 39 |
| 11 | Clause 34(b) | 41 |
| 12 | Clause 36A – Dividend Chargeable under section 2(22)(e) | 43 |
| 13 | Clause 42 – Furnishing of Form 61, 61A and 61B | 49 |
| 14 | Clause 43 | 68 |
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Revised Forms 3CA, 3CB, 3CD: Tax Audit Report
ICAI’s Revised Guidance Note on Tax Audit (2014 Edition) Applicable for AY 2021-22 also