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    CRK Publication On Overview On Revision of Tax Audit Already Filed

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    mradul dagur
    TAX Audit

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    CRK Publication On Overview On Revision of Tax Audit Already Filed

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    mradul dagur
    6 views5 pages
    TAX Audit

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    CRK Publication On Overview On Revision Of Tax Audit Already Filed

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    TAX Audit

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    6 views5 pages

    CRK Publication On Overview On Revision of Tax Audit Already Filed

    Uploaded by

    mradul dagur
    TAX Audit

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 5

    Overview On

    Revision Of Tax Audit Report


    Already Filed U/s 44AB
    www.crkandassociates.com
    Overview On Revision Of Tax Audit Report Already Filed

    The system and manner of conducting of Tax Audit u/s 44AB have changed drastically in recent time.
    We are now in electronic age, thus have to file the Tax audit Reports by e filing only. The journey of
    tax audit report started with manual filing, proceeded towards to No filing of the report and now the
    present e filing procedure. The e filing of Tax audit report is complete in itself, however the intention of
    this publication is to give a broad idea on revision of Tax Audit Report already uploaded just like there
    is a facility for revising of Income Tax Return.

    CAN TAX AUDIT REPORT ALREADY FILED CAN BE REVISED ?

    Yes, it can be revised. However 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.
    The revision of the Tax Audit report is directly related to taxation implications of the revised tax audit
    report. The reasons of subsequent events are defined, but some puerperal reasons are also justified
    to revise the Tax audit Report. Voluntarily filing a revised tax audit report income is not a time bound
    affair and it is well in the parameters with the compliance of the Income Tax. The Institute and the
    Ministry of Corporate Affairs have affirmed this position. In case of revision, the audit report should be
    given in the manner as required by the Institute in SA-560 (Revised), Subsequent Events. The
    Ministry of Corporate Affairs had also clarified that accounts can be revised to comply with technical
    requirements.

    MANNER & PROCEDURE OF REVISING TAX AUDIT REPORT ELECTRONICALLY

    Guidance Note of Tax Audit u/s 44AB of Income Tax Act-1961 prescribes that In certain cases,
    members are called upon to report on the accounts reopened and revised by the board of directors.
    The accounts of a Company once adopted at its annual general meeting should not normally be re-
    opened and revised. In case of revision, the audit report should be given in the manner suggested by
    the Institute.(Published in the Chartered Accountant, pp.655, February, 1985.Also refer to
    Revision/Rectification of Financial Statements, published in Compendium of Guidance Notes –
    Volume I). The Department of Company Affairs had also clarified that accounts can be revised to
    comply with technical requirements. 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.

    Further After uploading a Tax report if it came to the knowledge of auditor that his client is
    engaged in another business also this has been not disclosed to him at the time of the original Tax
    Audit. In such circumstances the tax auditor is having all the right to revise the original tax audit report
    at its first reporting rather than sitting idle and wait for any action from the Tax authority. It is better to
    www.crkandassociates.com
    compute the revised total taxable income of the client and also the revised tax liability. Many opined
    that the auditor may be at risk because of its first audit report, but this sword is having two way edges.
    The auditor has to choose the one, but the auditor is eligible to revise the same within own rights.

    A REVISED AUDIT REPORT CAN BE REVISED AGAIN?


    There is no limit to revise the Tax audit reports. The only suggestion from the guidance note and the
    department is that it should be in a manner suggested in SA- 560. After going through the Guidance
    Note of Tax Audit u/s 44AB of Income Tax Act-1961, it is very clear that Tax Audit report should not
    be normally revised. However, there is no bar in revising and revising again with a rider that it
    can be revised only to meet some technical requirements. It should be assured that the new
    revised report should carry the reference of old reports and should be signed in the current
    date. The date of the audit report is the date of signing the physical copy of the tax audit report
    /revised tax audit report.

    REASONS FOR REVISING TO BE MENTION


    In case, where a member is called upon to report on the revised accounts, then he must mention in
    the revised report said that the 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.

    CBDT PROVIDES FACILITY FOR REVISION


    The e-filing portal allows uploading such Revised Audit Report by the CA for the same PAN and
    Assessment Year. Further, the utility provided by CBDT for filling/ uploading of the TAX Audit report
    further added under heading “OTHERS” under uploading TAB. When we tick on “Other”, it will ask
    for further description/details. But here you can write anything & upload the same to the department
    website. You can also make comments/observations in respect of a particular class of Form No.3CD
    are to be mentioned in the e-form at a space provided therein. Alternatively, they can be uploaded as
    PDF files in the field ‘Upload other report’ of the portal.

    NO TIME LIMIT PRESCRIBED FOR REVISION OF TAX AUDIT REPORT


    The guidance Note & law also did not specify anywhere the period up to which revision can be done.

    SUBSEQUENT UPLOADING MAY BE BECAUSE OF JOINT AUDITOR


    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 the 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 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
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    his opinion in a separate report in case of a disagreement. Such separate reports are also to be
    uploaded to the portal.

    SA 560 IS TO ENSURE THE AUDITOR PERFORMS AUDIT PROCEDURES


    SA 560, Subsequent Events outlines the auditor’s responsibility in relation to subsequent events. For
    the purposes of ISA 560, subsequent events are those events that occur between the reporting date
    and the date of approval of the financial statements and the signing of the auditor’s report.
    The overall objective of SA 560 is to ensure the auditor performs audit procedures that are designed
    to obtain sufficient appropriate audit evidence to give reasonable assurance that all events up to the
    (expected) date of the auditor’s report have been identified, properly accounted for/or disclosed in the
    financial statements.
    SA 560 also covers events that are discovered by the auditor after the date of the auditor’s report but
    before the financial statements are issued. SA 560 says that if financial statements are affected by
    “events occurring between the date of the financial statement and the date of the auditor’s report, and
    facts that become known to the auditor after the date of the auditor’s report”, an auditor, “shall discuss
    the matter with the management, determine whether financial statements need amendment and if so
    inquire how the management intends to do the matter in the financial statements.”

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