ICSI Request for inclusion of CS Profession within the definition of “Accountant”

The Institute of Company Secretaries of India (ICSI) has requested for seeking inclusion of the profession of ‘Company Secretary’ within the meaning of the Company Secretaries Act, 1980 in the definition of “Accountant” given under Section 515(3)(b) of the Income Tax Bill 2025.

ICSI is a premier professional body established under an Act of Parliament, namely, The Company Secretaries Act, 1980 to regulate and develop the profession of Company Secretaries.

A Company Secretary, is a competent professional who undergoes exhaustive exposure provided by the ICSI through exhaustive study, examinations, rigorous training and continuing professional development programmes. A Company Secretary in practice after obtaining certificate of practice from ICSI undertakes various certification and audit services viz. internal audit, concurrent audit, secretarial audit etc.

Submission by ICSI

As your goodself is aware that the ecosystem of taxation laws in India has changed significantly with various amendments that have been taken place recently. Further, the new Income Tax Bill, 2025 could be seen as a roadmap to facilitate India’s vision of becoming a USD 5 trillion economy by 2027 and a developed nation by 2047. In this direction, ICSI as pioneer in promoting good governance has been partnering in various initiatives of the Government of India.

The Union Budget 2025-26 is structured around four engines of growth: Agriculture, MSMEs, Investment and Exports and transformative reforms, due to which would be spurring growth across various sectors viz manufacturing, IT, service sectors, MSMEs etc. demanding skilled professionals to make India a developed country. In continuation, industries and businesses require more qualified professionals for taxation and compliance purpose preventing dependency on any single profession and ensuring a competitive, quality-driven tax ecosystem, specifically in Tier 2 and Tier 3 cities to meet these requirements.

Here, we wish to submit that there is a need to widen the availability of professionals which will ensure timely tax filings, reducing compliance bottlenecks, and avoidance of repeated tax filing extensions, benefiting both businesses and the Government.

It is worth mentioning here that, a Company Secretary being an expert in corporate and tax laws, CS professionals bring high-quality interpretation and regulatory compliance, strengthening tax governance. Enabling CS professionals in tax practice will create wider pool of professionals for businesses, especially in smaller cities. Therefore, we request your goodself to kindly consider to include the profession of Company Secretaries in the definition of “Accountant” given under Section 515(3)(b) of The Income-Tax Bill, 2025.

Furthermore, this is a long pending issue for inclusion of Company Secretary at par with other professionals in the definition of “accountant”. In this regard, we would like to draw your kind attention towards various Reports of Parliamentary Standing Committee wherein it was suggested/recommended by the Committee to include other professionals in the definition of’ accountant.

We further wish to inform your goodself that the Company Secretaries have been authorized to issue various certification and conduct audit under various legislations issued by various Authorities which is attached as Annexure I.

The curriculum of Company Secretaryship Course includes, inter-alia, detailed study of Direct Taxation, Indirect Taxation and Financial Accounting as under:

CS Executive Programme (New Syllabus)

• Corporate Accounting and Financial Management [Group 1 Paper 4]
• Tax Laws and Practice [Group 2 Paper 7]

CS Professional Programme

• Goods and Services Tax (GST) and Corporate Tax Planning [Group 2, Paper 7.2]

Thus, vast exposure is provided to the Company Secretaries in the areas of taxation and accounts, enabling them to acquire proficiency in taxation and other related subjects.

The students of Company Secretaryship Course, after passing the Professional Programme examination, have to undergo compulsory training of Corporate Leadership Development Programme (CLDP). The CLDP also includes the training on GST and Practical Aspects of Direct Taxes. The Institute has following Certificate Courses in the areas of taxation for its members enabling them to acquire practical insight in taxation.

• PMQ Course on Direct Taxes (Post Membership Diploma).
• Certificate Course on GST.
• Certificate Course on Corporate Tax and VAT in UAE.

In view of the various recognitions available to Company Secretaries and the detailed coverage of the Accounting and Taxation papers in the curriculum of Company Secretaryship Course, it is submitted that Company Secretaries are very well conversant with the technicalities of the accountancy and taxation and are at par with other professionals.

In light of the above, we request your goodself to include the profession of ‘Company Secretary’ within the meaning of the Company Secretaries Act, 1980 in the Definition of “Accountant” given under Section 515(3)(b) of The Income-Tax Bill, 2025 which may read as under:

“accountant” means a chartered accountant as defined in section 2(1)(b) of the Chartered Accountants Act, 1949, who holds a valid certificate of practice under section 6(1) of that Act, or a company secretary as defined in section 2(1)(b) of the Company Secretaries Act, 1980, who holds a valid certificate of practice under Section 6 (1) of that Act, or any person having such qualifications as the Board may prescribe, for the purposes specified in this behalf.

We shall be pleased to provide any further information as may be desired by your good self.

We look forward to an opportunity for a personal meeting at any time and place convenient to your good self for explaining our submissions.

For Official Letter Download PDF Given Below: