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Completing Income Tax Return without Completing Tax Audit Report

The extension of date for obtaining and submitting the Tax Audit Report till 30th November 2014 for the Assessment Year 2014-15 without extending the due date to file the Return of Income has created many concerns in the minds of Chartered Accountants.

The Income Tax Return formats also now modified to include the new row asking “if liable for Tax Audit u/s 44AB is YES, whether the accounts have been audited by the Accountant ? If YES, furnish the following information” clearly indicating that the return of income needs to be filed before 30th September, 2014 and can be filed without filing of Audit Report.

Various concerns are raised regarding how to complete the Income Tax Return without completing the Audit Report. If we analysis the Tax Audit Report Format, we can divide the clauses under main four categories comprising of Basic Information, Information regarding Accounts and Accounting Policies, Information relating to Income Computation and Other Information.

To finalise the Income Tax Return, we need to concentrate mainly on the 3rd category which ask for information relating to Income Computation which covers the following clauses –

Sr.No.  Clause No.      Particulars

1          12        Whether Profit and Loss Account includes profit assessable on presumptive basis

2          15        Capital Assets converted into Stock in Trade

3          16        Amounts not credited to Profit and Loss Account

4          17        Whether land and Building transferred during year

5          18        Depreciation allowable

6          19        Amounts debited to Profit and Loss and admissible under Income Tax

7          20(a)    Sum paid to employees as bonus or commission otherwise payable as profits or dividend

8          20(b)    Contributions received from employees under various Schemes

9          21(a)    Details of debited to Profit and Loss such as Personal, Capital, Advertisement expenses

10        21(b)(i)            Amounts inadmissible u/s 40(a)(i) – Payment to Non-resident

11        21(b)(ii)           Amounts inadmissible u/s 40(a)(ia) – Payment without TDS / Late Payment

12        21(b) Others    Amounts inadmissible u/s 40(a) – Payments towards

13        21( c )  Amounts debited to Profit & Loss Account & inadmissible, with computation, under section

14        21(d)   Disallowance or Deemed Income u/s 40A(3) / (3A)

15        21(g)    Particulars of Liability of Contingent Nature

16        21(h)    Expenditure disallowable u/s 14A

17        21 & 22           Amounts inadmissible – Payments towards

18        23        Particulars of Payments made to related persons 40A(2)(b)

19        24        Deemed Profit

20        25        Chargable u/s 41 with computation

21        26        Liabilities allowable and disallowable u/s 43B

22        27(a)    Cenvat credit summary

23        27(b)    Prior Period Income and Expenditure credited or debited to Profit and Loss

24        28        Income u/s 56(2)(viia) – Receipt of Shares without adequate consideration

25        29        Income u/s 56(2)(viib) – Consideration Recd in excess of FMV for issue of Shares

26        32        B/f Lossses

27        33        Deduction under Chapter III or VI-A

Once the information on above clauses are confirmed and audited, there will be no need to revise the return after finalizing of the Audit Report. We should concentrate on compilation of the information required by these clauses and need not waste time in filling up the actual report.  A Sample format of the details required for each clause is made available

Everybody is required to suggest ways and methodology to complete the filing of income tax return without completing Audit Report which will help all to do work efficiently as well as smoothly and will not put us in a panic situation.




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