CA Sudir Halakhandi

One more controversy is going on with respect to uploading of the financial statements i.e. “Balance sheet and profit and loss account” with Form 3CD/ 3CB and this controversy is related to the physical signatures on the “Financial statements” before uploading the same on the site. 50% of the questions received by us are related to this problem hence we are discussing the same here today.

The first option is get the signature of the client and the CA on the financial statements, get it scanned on the in PDF form and upload it. If you are doing it then there is no controversy and perfectly you are taking an uncontroversial course of action in this respect.

The second option is to prepare an unsigned PDF file and upload it and in that case scanning is not required and you can convert the word file directly in PDF. There are views that this is also a correct process and convenient also because these financial statements are uploaded with the digital signatures of the CA and approved by the assessee with the DSC. The timing of taking signature of the assessee on financial statements and then scanning it is saved. This is the second view.

We are the follower of the first option and while uploading our report we are following the same process. The first option is perfectly correct hence if you are following it then there is no need for you to give any heed to this controversy since it is perfectly OK we are following it but since here we are sharing only our practical experience with the readers with claiming any expertise hence we are not disregarding the second option totally.

The first reason for opting the second option is wastage of time in getting the signatures of the assessee on the financial statements is not a valid reason because if you have completed the audit then taking signature of the client on Financial statements are mandatory and even after that you can upload the tax audit report legally. If you want to upload the audit report and financial statements without taking the signatures on the “Financial statements” then this is not valid legally. Practically by opting the second method you are merely saving the time of taking scanned copy of the Financial statements because in any case you cannot upload the Financial statements without taking signatures on it. If you are doing it then you may be extra ordinary practical but legally not correct.

One thing may be noted here that you can also sign the Financial statements with your DSC and also get it signed by the assessee with DSC before uploading the same but submitting the Financial statements with DSC of the CA and approving it with the DSC of the assessee as per the current practice of the uploading at IT site is not alternate of signing the Financial statement. There is a system of signing the PDF file with the DSC and some software are available in this respect and in that case you will find a mark of “digitally sign” on the financial statements and this is also the correct method of uploading the financial statements.

So before taking any decision in this respect please consider the facts mentioned above and then decide the right course of action.


-CA Sudhir Halakhandi -CA Abhas Halakhandi

“Halakhandi”, Laxmi Market, Beawar-305901(Raj)

Cell- 9828067256, MAIL –

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  1. vicky says:

    i have uploaded balance sheet with DSC but not Profit & loss A/c. So can it possible to reupload Profit & loss a/c.

    Replay me as soon as earlier

    Vicky Kapadiya

  2. A.C.NAGARAJA PRASAD, B.COM., F.C.A., says:

    AUDIT REPORT” appearing in ICAI portal
    (Developed by Direct Taxes Committee of ICAI in consultation with the Officials of Directorate
    of Income-Tax (Systems)

    The point raised above is specifically dealt with.

    “3. Whether it is mandatory to upload a scanned copy of signed Balance Sheet, P&L and other documents?
    Balance Sheet, Profit and Loss Account in Word, Excel Format, etc signed as “sd/-” can be converted in to ‘.pdf’ file and uploaded on the portal. However, the auditor should maintain the physically signed Audited Report in his records and ensure from that there is no difference between physical report and PDF file uploaded.”

    The above answer gives us a better and slightly easier solution especially when the due date is nearing. Anyhow, the Govt. should ease the formalities & extend the date by at least two months after rectifying the e-utilities.
    Best wishes & Regards
    ACN Prasad

  3. yogesh bhagat says:

    i m happy with third option that make the dsc sign of ca and assessee on the pdf file by using the software. Which will save the time for taking print making physical signature scanning document.

    So if option is available, it will be very beneficial, since it will defenitly help at the time of rush and last min……

  4. Sunil Bhageria says:

    Sir, I have one query on online submission of form 3CD and other report. In our case domestic transfer price is applicable hence for 3ceb to be taken the last date for filing return in such case is 30 th Nov. so can be submit the form 3cd and other reports under section 115JB,80-IC, etc on 30 Nov. only. Our CA is asking that he has to upload tax audit(form 3CD) by 30 th September irrespective of due date of filing return by 30 th Nov. Pl guide me and help.

    Thanks in advance.


    Sunil Bhageria

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