CA Sudhir Halakhandi

New Format Tax Audit Report- The Midyear Changes in Tax Audit Report in Form 3CD Are Undesirable

The Central Board of Direct Taxes has issued a new set of formats for Tax audit report in the form of Form 3CA, Form 3CB and Form 3CD thorough Notification No. 33/2014 dated 25/07/2014. In all they have introduced 24 changes and seek more information from the tax auditor. There is no dispute about the right of our lawmakers (here the CBDT) to draft these formats and ask the information which in their opinion is required for the task in hand but the timing of introduction of these changes is not only crucial and sudden but irritating also.

See here, the financial year related to the assesseement year 2014-15 has come to an end on 31/03/2014 and the audits for the financial year under consideration can be started any time on or after 01/04/2014 hence the formats of the audit report in this respect should be introduced on or before 1/04/2014. Why two sets of audit report in a single assessment year.

Here, the question is not about the requirement and usefulness of the information newly asked in the format of Tax audit report and form 3CD but there should be a systematic approach which should strictly be followed by the regulators and the Law makers also. If they have taken time to draft these revised formats and the task was not completed on 01/04/2014 then the applicability should also be declared from the Next year.

Further the law makers have enormous resources at their disposal but see, there is always delay in introduction of the ITRs for e-filing every year. The schema for Tax audit report was changes on weekly basis in 2013. It seems there are bottlenecks and these should be overcome first before making the system more complicated by introducing the midyear changes.

The Format of audit reports, the Schema of E-filing ITRs should be introduced on or before 1st Day of April every year because meeting this deadline is not an impossible task so that the concerned Taxpayers and professionals can plan their work accordingly. This is very simple and reasonable demand and it should be considered in the same way.

No doubt that our Law makers have very difficult task in their hand because the number of taxpayers is too large and accordingly there may be lot of planning to be done to regulate the whole system of Direct taxation but the attitude “when procedure is ready at our end we will introduce it” should be changed and this is not very urgent matter which required to be introduced in middle of the year.

The New formats of Tax audit report should be made applicable for the assessment year 2015-16 for the sack of only one reason that these should not be introduced in middle of the year.


-CA Sudhir Halakhandi,  -CA Abhas Halakhandi

Halakhandi And Company, Chartered Accountants

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

Cell- 9828067256,  MAIL [email protected]

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  1. S PRAKASH says:

    Kindly remember days when the uploading of the audit report was introduced in the last minute.Why the CA’s did not raise the VOICE then? Why only now they are against the amendment to the Form 3CD,3CA and 3CB? In the interest of the tax paying public let the CBDT clarify as to why the changes has been made in the last hour?The CBDT never cares for the VOICE of the tax paying public, let CBDT think in the favor of the assessee and not in the interest of the CA.Is the Finance Department and CBDT work only of the CA’s or it is worried about the tax paying community at large? Let the CBDT think of increasing the TAX BASE,and voluntary filing of returns by the assessee and removing the hurdles of certifications from the CA for filing the returns.In my experience the Departmental officials are more intelligent than any tax professionals in unearthing the block money.

  2. CA NARESH GUPTA says:

    a good and much desired thought.
    my question is when i am allowed 4/6 months for filing my return,
    how can govt. curtail my right by reducing the said time by
    introducing amendments very late or releasing the schema of itr return

    or law maker think that we are overstaffed like them who can perform the needful in two months
    instead of 6 months.

  3. Kamal says:

    Dear Sir,

    Solely agree with author why this kind of changes implemented by regulators in mid of year, it should be applicable for next year and the same voice should also be raised by ICAI.

  4. S K GUPTA says:

    Modi ji said Achhe Din aagay. But For CA community bad days have started as CBDT has changed format of TAx audit report at 11th hour.Neither client nor professional are ready for change .CA Institute should take matter with FM

  5. CA Ashok Aggarwal says:


    Regarding efiling contact details too system should send PIN to both primary contact details as well as to secondary contact who is generally CA to expedite the process of filing and/or processing efiled returns

  6. CA Ashok Aggarwal says:


    Apart from changes introduced the software be such that picks inforamation automatically like in case of clause relating to loan and deposites accepted/repaid. Besides there is no option introduced to copy paste from one clause to another to save time and mistakes of typing repeatedly. In samae manner the figures like calculation of GP ratio and other ration the system should take figures automatically from another annexures part of this report.

    Ashok Kumar Aggarwal
    Moga (Punjab)

  7. S K Gupta says:

    CBDT should increase time for efiling of tax audit reports up to 30.11.14 and immediately load utility on website of Dept

  8. M K U Varma says:

    According to me every assessee and CA and Tax professional shouls vehemently oppose any achnges made in short notice. Should also demand CBDT to notify the relevant forms of ITRs applicabl for a particular Asst. Year by 1st of April of that AY so that if any assessee wants to file his return on 1st April, we must be able to do and the ITD portal should be ready to accept the return uploaded.

  9. Avinash Rawani says:

    It is very unfortunate on the part of the profession. Needs a strong representation in this regard. The Form should be made applicable from FY 2014-15 onwards as many tax audits would have been completed and filed. There should be a system of notifying all the ammendments at a time in the month of January or February before the start of the financial year.

  10. CA.D.ANANDHAN says:

    CBDT has taken decision at 11 th hour only. Our forum should be strongly opposed to introduce the last minute changes. All the forms and rules should be implemented on or before end of the previous year

  11. CA ANIL D. SARAF says:

    The Law Makers (actually Law Destroyers) unnecessarily making the E-Filling System complicated.
    1. When Assessee logged in with the ID and Password, there is no need for code verification every time.
    2. The fact is that 95% E-Filling are done by the Professionals in consultation with the Assessee and not by the Assessee directly. 80% Assessees do not have any E-Mail ID. In such a situation, Validation of E-Mail is just creating complexities.
    3. India is Master in Software Development Area. Everybody knows that since 1st of April every year, the Assessment Year Started. Why don’t the Income Tax Authorities issue new schema and tax return form on midnight of 31st March every year.
    4. The Government machinery expect high quality of professional work from the Practitioners but, there own approach is very absurd.

    We have to protest these kind of activities. I request to our Institute to take some harsh steps in this connection.

  12. harsh says:

    India Law makers be he of congress or BJB (Chidambaram or Jetley) no one is concerned with the professionals and assesse (public). what they have thought is that all in India are liers, thief. So we are paying the cost to be indian.

  13. mudit agrawal says:

    if one has finalized and signed audit reports before 25th july and the assesse has given those in Sales tax department, banks etc. Please suggest me that which date to write in the audit report if I efile today

  14. Paras Bafna says:

    There is a problem with law makers also. They can follow the law even beyond its spirit but generally fail in following the unwritten and commonly understood rules.

  15. MANDEEP SINGH says:

    There may be certificate from all professionals who are authorized u/s 288(2). following language this certificate need to be contain:
    I certified that all vouchers/bills regarding sale,purchases, expenses, household expenses & regarding capital addition have physically verified by me. If any wrong particular find out by A.O during assessment then I will be responsible for action under IPC.

  16. MANDEEP SINGH says:

    Why CBDT is not understand actual position? There is no need of certificates for Non-corporate assessees. Department need only revenue not certificates.These certificates till today present in income tax without evaluating its output since 1984.
    If government wants revenue then these certificates need to be omitted from income tax act. These provisions only financial burden & wastes of time of indian assessees except this nothing else.

  17. anand says:

    They make changes even in the last week of Sept. We are fortunate they have made two months in advance. In fact I had prepared about 20 audit reports and suddenly the changes have been announced. I have to change all these. But at least they notify the change which they are not supposed to do. For instance one mobile and one e-mail id for four assessees and then for ten assessee were not notified.

    We expect the unexpected only. The department notify the forms late and collect interest u/s 234B in the intervening period. Why can’t the department notify the forms before 31st March

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