Clause 44 of Form 3CD for suggestive note by tax auditor

By CA Satish Agarwal

(i) (a) As informed by assessee that information’s as reported under clause 44 of form 3CD are based on information’s as extracted from accounting software (GST report)

(b) However this may not be 100% accurate as accounting software used by assessee is not configured to generate report as required under clause 44 in absence of prevailing statutory requirement under Income tax Act, 1961, GST, 2017, under any other law + software (system) is not capturing information’s against entity as falling under composition scheme (supply) with ineligible credit.

(ii) (a) We have verified the statement as prepared by assessee in accordance with Auditing Standards generally accepted in India + test checked as based on concept of materiality and concept of reasonable assurance.

(b) However as per accounting entries as passed in accounting software it’s not possible to extract desired details to be reported under clause 44 of 3CD.

(c) Hence we are unable to comment on accuracy of information as provided by assessee.

(iii) Assessee has informed that “Expenditure relating to entities not registered under GST” is including the import of goods, import of services and services from unregistered suppliers where GST liability under RCM has been discharged.

(iv) Assessee has informed that difference between Clause 2 (Total expenditure) and sum of clause 6 and 7 on account of depreciation, bad debt and expenditure, like salary is not supply in accordance GST, 2017 and also total expenditure as per column 2 is including capital expenditure.

(v) As communicated by assessee the details in accordance with rule 56 of CGST Rules are to be furnished during assessment proceedings before AO if demanded.