FREQUENTLY ASKED QUESTIONS (FAQs) ON e-FILING OF TAX AUDIT REPORT
(Developed by Direct Taxes Committee of ICAI in
consultation with the Officials of Directorate of IT (Systems)
Note: This document deals with those FAQ’s
which are not covered in the e-filing portal. The members may visit the www.incometaxindiaefiling.gov.in for other
FAQ’s. [Go to home page of www.incometaxindiaefiling.gov.in,
click on
‘Help’ menu at right topmost corner of the page, and then click on the link as
may be considered necessary]
The procedure of e- filing is explained at
the following path of e-filing website:
However,
the procedure in brief is mentioned below:
Step-
I Registration on e-filing portal Action by Chartered Accountant
a) Access www.incometaxindiaefiling.gov.in
b) Click on ‘Register Yourself’ tab and
select the user type under Tax Professional as ‘Chartered Accountant’
c) Enter Basic details:
ü Details of membership of ICAI: MRN, Enrollment date
ü
Personal Details: Surname, Middle Name, First Name, Date of Birth, PAN, E-mail id
ü
Digital Signature Certificate: upload .pfx file or USB token
ü
Click ‘Submit’
d) After successful submission of above
basic details, enter details in registration form:
ü
Set Password.
ü
Set primary secret question and answer thereof.
ü
Set secondary secret question and answer thereof
ü
Enter contact details: Landline no., mobile no; alternate
number; e-mail id & alternate e-mail id;
Fax number
ü
Postal Address
ü
Subscribe to e-mail and alerts
ü
Captcha Code
After successful submission of all above
details, the user will receive a confirmation e-mail containing an activation
link. The user account will be activated as soon as the user triggers that
link, thereby updating the database of Income-tax Department. An SMS will also
be sent at the registered contact number of the user notifying that a
confirmation mail was sent to his/her registered e-mail id.
Step-
II Add Chartered Accountant Action by Assessee
a) Assessee is required to login into his
account by entering user id and password at www.incometaxindiaefiling.gov.in
b) Go to ‘My Account’ tab and select ‘Add
CA’
c) Enter MRN of the CA. After entering
correct 6 digits MRN of CA, the name of CA will automatically get prefilled.
d) Select the Form no. for which CA is
supposed to be added.
e) Select Assessment Year
f) Enter the image of the Captcha code
g) Click ‘Submit’
After successful submission of above, a
message will be displayed notifying the addition of CA in assessee’s profile.
Step-
III Submit Tax Audit report Action by Chartered Accountant
After successful uploading of tax audit
report, the said form will go to assessee for approval.
Step-
IV Approval or Rejection of uploaded tax audit report
Action
by Assessee
a) Login the account and navigate to ‘Work
list’ tab (Assessee will be able to view list of forms submitted by Chartered
Accountant along with attachment)
b) Click on ‘View Form’
c) Assessee can verify the form and
approve/reject the form (other than ITR).
d) The acceptance of the form (other than
ITR) by the assessee is to be made under his/her Digital Signature.
e) If assessee is rejecting the form,
reason for such rejection has to be provided.
An email will be sent to the registered
e-mail id after successful submission of the form along with the
acknowledgement number.
Form No. 3CA requires the tax auditor to
annex a copy of the Statutory Audit Report along with the copy of audited
Profit and Loss Account/ Income & Expenditure Account, audited Balance
Sheet and documents declared by the said Act to be a part of / or annexed to
the Balance Sheet and Profit and loss Account/ Income & Expenditure
Account. Accordingly, the same are required to be uploaded.
With regard to Form No.3CB, the tax auditor
is required to annex the audited Balance Sheet, Profit and loss account /Income
& Expenditure Account along with notes to accounts and schedules, if any,
forming part of Balance Sheet, Profit and loss account /Income & Expenditure
Account.
Balance Sheet, Profit and Loss Account in
Word, Excel Format, etc signed as “sd/-” can be converted in to ‘.pdf’ file and
uploaded on the portal. However, the auditor should maintain the physically
signed Audited Report in his records and ensure from that there is no
difference between physical report and PDF file uploaded.
E-filing portal verifies the Name of Member
and Date of Birth entered in Registration Form from ICAI Database and also PAN
Database. In case there is difference / mismatch of details between the two
Databases the portal will not allow registration. In case any member is facing such
difficulty, please refer to procedure given in the following link
Sections 44AD, 44BB, 44BBB & 44AE
provide that in specified cases the assessee is required to get his accounts
audited and furnish the report of such audit as required under section 44AB.
Therefore, e-filing is applicable to such audits also.
The present E-filing portal does not
provide field to mention FRN, however, the department is in the process of
enabling this facility. Till the utility is configured to allow entering of
FRN, members need not mention their FRN.
Comments / observations, if any relating to
the clauses may be given in Form 3CA/3CB subject to space provided therein.
Alternatively, they can be uploaded as PDF file in the field ‘Upload other
report’ of the portal.
The e-filing portal allows the report to be
uploaded by a single auditor. Therefore, the joint auditors may mutually agree
and decide the auditor who shall upload the report. However, all the joint
auditors should sign the hard copies.
As per the ICAI’s “Guidance Note on Tax
Audit u/s 44AB of the Income-tax Act, 1961”, it is possible for the assessee to
appoint two or more chartered accountants as joint auditors for carrying out
the tax audit, in which case, the audit report will have to signed by all the
chartered accountants. As per Standards on Auditing 299 (Responsibility of
Joint Auditors) issued by ICAI, normally, the joint auditors are able to arrive
at an agreed report. In such case, the physical copy should be signed by all
the auditors. Thereafter, any one of them may upload the report.
However, where the joint auditors are in disagreement
with regard to any matters to be covered by the report, each one of them should
express his own opinion through a separate report. A joint auditor is not bound
by the views of the majority of the joint auditors regarding matters to be
covered in the report and is required to express his opinion in a separate
report in case of a disagreement. Such separate reports are also to be uploaded
on the portal.
Comment of CA Nitesh More – You have to follow the below mentioned steps:
a) Combine data of two B/S, P/L, tax audit report and
submit as one
b) If tax audit conducted by two CAs, any CA can submit.
c) It is advised to attach physical copies of both Tax
Audit Reports too, for disclosure of the fact that (i) two CAs have done Tax
audit and (ii) that CA who is filling had relied on the work of other CA
In case of revision, the audit report
should be given in the manner suggested by the Institute in SA-560 (Revised)
“Subsequent Events”. It may be pointed out that report under section 44AB
should not normally be revised. However, sometimes a member may be required to revise
his tax audit report on grounds such as:
(i) Revision of accounts of a company after
its adoption in annual general meeting.
(ii) Change of law e.g., retrospective
amendment.
(iii) Change in interpretation, e.g. CBDT’s
circular, judgments, etc.
(iv) Any other reason like system/software
error requiring change in report already uploaded.
In case, where a member is called upon to
report on the revised accounts, then he must mention in the revised report that
the said report is a revised report and a reference should be made to the
earlier report also. In the revised report, reasons for revising the report
should also be mentioned.
The e-filing portal allows uploading such
Revised Audit Report by the CA for the same PAN and Assessment Year.
As per ICAI Council Guidelines
No.1-CA(7)/02/2008, dated 8th August,2008, a member of the Institute in
practice shall not accept, in a financial year, more than the 45 tax audit
assignments under Section 44AB of the Income-tax Act, 1961. However, audits
conducted under sections 44AD and 44AE shall not be included in this limit.
Since, the Income-tax Act, 1961 does not
provide any limit on number of tax audits assignments which can be undertaken
by a Chartered Accountant the e-filing portal does not provide any restriction.
However, members are required to comply with the prescribed ceiling limits.
As per Chapter VI of Council General
Guidelines, 2008 (Tax Audit Assignments under Section 44AB of the Income Tax
Act, 1961), a member of the Institute in practice shall not accept, in a financial
year, more than the specified number of tax audit assignments as prescribed
under Section 44AB of the Income Tax Act, 1961. The specified number of tax
audit assignments under Section 44AB of the Income Tax Act, 1961 is 45.
It is further provided in Chapter VI of
Council General Guidelines, 2008 that in case of firm of Chartered Accountants
in practice, specified number of tax audit assignments means 45 tax audit
assignments per partner of the firm, in a financial year.
Therefore, if there are 10 partners in a
firm of Chartered Accountants in practice, then all the partners of the firm
can collectively sign 450 tax audit reports. This maximum limit of 450 tax audit
assignments may be distributed between the partners in any manner whatsoever.
For instance, 1 partner can individually sign 450 tax audit reports in case
remaining 9 partners are not signing any tax audit report.
It is needless to say that the tax audit
assignment should be in accordance with the Standard on Quality Control (SQC)
1: Quality Control for Firms that Perform Audits and Reviews of Historical
Financial Information, and Other Assurance and Related Services Engagements
To increase the computer processing speed
all the previous versions of java be removed from the computer. To use the
e-forms utility install Java Runtime Environment Version 7 update 13 (jre 1.7
is also known as jre version 7) or https://incometaxindiaefiling.gov.in
CBDT Notification No. 34/2013 dated
1-05-2013 provides that the rules prescribed therein shall be deemed to have
come into force with effect from the 1st day of April, 2013. Accordingly, even
if ITR has been filed prior to issuance of said Notification, Tax Audit report
is required to be e-filed separately.
Date on which the report is physically
signed by the Auditor shall be the date of audit report.
E-filing of ITR and Tax Audit report are
independent actions. However, it is advisable to first upload tax audit report
and then file IT return.
Comment of CA Nitesh More – In my view, Date of furnishing TAR to department is to be
mentioned in ITR. So TAR is to be filed first.
The trust should first fill the status and
then PAN.
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