Revised Formats of Tax Audit Report: Forms 3CA, 3CB and 3CD (FY 2017-18/ AY 2018-19)
CBDT has notified revised Tax Audit Report Forms (3CA, 3CB, 3CD) from time to time. On 20 July 2018, Form 3CD has been further revised (applicable from 20 Aug. 2018) to expand scope of reporting relating to GST, GAAR, SFT, Cash Transactions, Transfer Pricing, etc., for FY 2017-18/ AY 2018-19. However, subsequently CBDT has partly deferred implementation of revised Form 3CD by keeping Clauses 30C and 44 in abeyance, till 31 March 2019.
CBDT has notified substantial changes in the Format of Tax Audit Report (Form 3CD), i.e. new/ revised reporting requirements relating to GST, SFT, Cash Transactions, Transfer Pricing, etc. have been prescribed, applicable w.e.f. 20 Aug. 2018.
CBDT has notified amendments in “Clause 31 relating to particulars required under IT Section 269SS/ 269T” in the Tax Audit Report Form 3CD prescribed under IT Section 44AB, w.e.f. 19 Jul. 2017.
Clause 31 has been substituted to include reporting requirements introduced through i) amendments in Section 269SS in respect of payments relating to immovable property transactions and ii) amendments in section 269T in respect of reporting of loans/ deposits transactions even by recipients (i.e. so far only payer was required).
It may also be noted that the revised Forms 3CA, 3CB, 3CD, 3CEB, 29B etc. are now required to be uploaded in ‘xml’ format after signing digitally at the e-filing website of Income Tax Deptt.
The CBDT has further amended/ revised Form 3CD, applicable from AY 2017-18 (i.e. corresponding to Financial/ Previous Year 2016-17) to facilitate changes relating to ICDS Reporting Adjustments thru Income-tax (23rd Amendment) Rules, 2016 vide Notification No. 88/2016.
CBDT has amended Form 3CD w.e.f 1 Apr. 2017 by substituting clause 13(d) with new clauses 13(d), (e) and (f) requiring reporting of the adjustments and disclosures mandated by the ICDS.
Amended clause 13(d) requires reporting by tax auditor on adjustment required in profits or loss for complying with the ICDS provisions. New clause 13(e) requires ICDS-wise reporting of the adjustments made in profit or loss for ICDS compliance, showing clearly increase/ decrease in profits as well as the overall net effect of such adjustments. Further, clause 13(f) requires reporting of the ICDS-wise disclosures.
The CBDT, in exercise of the powers conferred by section 295 read with section 44AB of the Income-tax Act, 1961 (43 of 1961), had amended Form No. 3CA, Form No. 3CB and Form No. 3CD, vide Notification No. 33/2014 w.e.f. 25th July, 2014. These forms can be utilised for tax audit reports pertaining to AY 2015-16 and 2016-17.
Revised Tax Audit Report Forms (3CA, 3CB, 3CD) Applicable w.e.f. 20 Aug. 2018/ 1 April 2019
* It may be noted that Form 3CD has been recently revised on 20 July 2018 (as attached above) applicable w.e.f. 20 Aug. 2018. However, on 17 Aug. 2018, the CBDT has deferred implementation of newly inserted Clause 30C and 44 upto 31 March 2019 (i.e. the same shall be applicable w.e.f. 1 April, 2019), based on representations from stakeholders, like ICAI, etc.
Tax Audit Report Form 3CD Applicable during 19 July 2017 to 19 Aug. 2018
Form 3CD was earlier revised in July 2017, which remained applicable during 19 July 2017 to 19 August 2018, as attached here-under: