ICAI issued Guide on changes in Form 3CD w.r.t. Notification No. 33/2018

ICAI Direct Tax Committee has issued Implementation Guide w.r.t. Notification No. 33/2018 dated 20.07.2018 effective from 20.08.2018.

Recently, the CBDT vide Notification No. 33/2018 dated 20th July, 2018 has made revisions to Form No. 3CD wherein it requires additional requirements to be reported. The additional inclusions in the said form has increased the scope of tax audit significantly and requires various additional procedures to be performed with due diligence before reporting on these additional requirements.

The Central Board of Direct Taxes, vide Notification No. 33/2018/F No. 370142/9/2018-TPL dated 20th July 2018, notified amendments to Form No. 3CD enhancing substantially the reporting requirements and the role of tax auditor as various new clauses/sub clauses have been inserted, major amendments have been made and additional disclosures are to be reported. In July 2014, the CBDT had amended the formats of tax audit reports, thereby expanding the scope of tax audit. Since significant changes were made in the format of tax audit reports for which members were to be guided, the Direct Taxes Committee of ICAI had issued the Seventh Edition of the Guidance Note on Tax Audit u/s 44AB of the Income-tax Act, 1961 in the year 2014.

Afterwards, various changes were made in the Tax Audit Form by the CBDT in the year 2016 & 2017 which are yet to be incorporated in the Guidance Note on Tax Audit u/s 44AB of the Income-tax Act, 1961. As the revision of the Guidance Note on Tax Audit requires substantial time and efforts, while the notification dated 20th July 2018 became effective in a short period of time from 20th August 2018, therefore, the Direct Taxes Committee of the ICAI decided to bring out at the earliest an implementation guide with respect to the notification dated 20th July 2018. In the meantime, vide Circular No. 6 of 2018 dated 17th August 2018 two of the clauses included in notification dated 20th July 2018 were kept in abeyance till 31st March 2019.

This Implementation Guide is, therefore, in respect of amendments made in Form No. 3CD vide Notification No. 33/2018, dated 20th July 2018 and made effective from 20th August 2018.

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