Sample Disclosure as per Income Computation and Disclosure Standards (ICDS) for Tax Audit report
|Sample Disclosure for ICDS Income Tax– Applicable for FY 2016-17 |
By CA Naman Shrimal
|ICDS I – ACCOUNTING POLICIES|
|Check Points||Points to be fed in 13(f)|
|1.||All significant accounting policies adopted by a person.||Financial Statements||Mercantile method of accounting employed. Expenses and Income are accounted for on accrual basis as per generally accepted accounting principles in India|
|2.||Any change in an accounting policy which has a material effect shall be disclosed. The amount by which any item is affected by such change shall also be disclosed to the extent ascertainable. Where such amount is not ascertainable, wholly or in part, the fact shall be indicated. If a change is made in the accounting policies which has no material effect for the current previous year but which is reasonably expected to have a material |
effect in later previous years, the fact of such change shall be appropriately disclosed in the previous year in which the change is adopted and also in the previous year in which such change has material effect for the first time.
|3CD – Clause 13 (b), (c)||Applicable only if some change is there|
|ICDS II – VALUATION OF INVENTORIES|
|1.||The accounting policies adopted in measuring inventories including the cost formulae used. Where Standard Costing has been used as a measurement of cost, details of such inventories and a confirmation of the fact that standard cost approximates the actual cost.||3CD – Clause 14 (a) |
|As per Cost or NRV whichever is lower on |
Specific Identification method/Weighted Average/ First In First Out valued as per Standard Cost/Retail Method
Inventory has been valued as per exclusive method however
|2.||The total carrying amount of inventories and its classification appropriate to a person.||3CD – Clause 35||Total amount of inventory with bifurcation |
· Raw Material
· Finished Goods
(Clause of financial statement may also be referred )
|ICDS III – CONSTRUCTION CONTRACTS|
|1.||· The amount of contract revenue recognised as revenue in the period; and |
· the methods used to determine the stage of completion of contracts in progress.
|Management certificate||· Total Amount recognized as contract revenue in the current financial year is Rs XX,xxx |
· Proportion of contract cost with respect to estimated contract cost method/surveys of work performed method/physical proportion method has been used for calculation of percentage of completion
|2.||A person shall disclose the following for contracts in progress at the reporting date, |
· amount of costs incurred and recognized profits less recognized losses up to the reporting date;
· the amount of advances received; and
· the amount of retentions.
|Each contract needs to be looked upon. Advance as on BS to be reported||Amount to be shown|
|ICDS IV – REVENUE RECOGNITION|
|1.||In a transaction involving sale of good, total amount not recognised as revenue during the previous year due to lack of reasonably certainty of its ultimate collection along with nature of uncertainty.||Scrutiny||Not Applicable/The Rs XX,xx amount was not recognized due to lack of reasonable certainty|
|2.||The amount of revenue from service transactions recognised as revenue during the previous year.||Scrutiny |
Each contract needs to be looked upon. Advance as on BS to be reported
|Amount to be shown|
|3.||The method used to determine the stage of completion of service transactions in progress.||Proportion of contract cost with respect to estimated contract cost method/surveys of work performed method/physical proportion method has been used for calculation of percentage of completion|
|4.||For service transactions in progress at the end of previous year |
· amount of costs incurred and recognised profits less recognised losses upto end of previous year;
· the amount of advances received; and
· the amount of retentions.
|ICDS V – TANGIBLE FIXED ASSETS|
|1.||Description of asset or block of assets||3CD – Clause 18||As per clause 18 of Tax audit report|
|2.||Rate of depreciation|
|3.||Actual cost or written down value, as the case may be|
|4.||Additions or deductions during the year with dates; in the case of any addition of an asset, date put to use; including adjustments on account of— |
· Central Value Added Tax credit claimed and allowed under the CENVAT Credit Rules, 2004;
· change in rate of exchange of currency;
· subsidy or grant or reimbursement, by whatever name called
|6.||Written down value at the end of year|
|ICDS VII – GOVERNMENT GRANTS|
|1.||Nature and extent of Government grants recognised during the previous year by way of deduction from the actual cost of the asset or assets or from the written down value of block of assets during the previous year.||Scrutiny|| |
|2.||Nature and extent of Government grants recognised during the previous year as income.||As per Profit & Loss Account|
|3.||Nature and extent of Government grants not recognised during the previous year by way of deduction from the actual cost of the asset or assets or from the written down value of block of assets and reasons thereof.||MRL, Fixed asset register/schedule and grants received|
|4.||Nature and extent of Government grants not recognised during the previous year as income and reasons thereof.||MRL & check grants received from financial|
|ICDS IX – BORROWING COSTS|
|1.||The accounting policy adopted for borrowing costs.||Scrutiny||· In case of specific borrowing, actual borrowing cost has been capitalized on that asset |
· In case of general borrowing, borrowing cost is being capitalized as per Para 6 of ICDS IX.
|2.||The amount of borrowing costs capitalised during the previous year.||Financials||Amount needs to be disclosed|
|ICDS X – PROVISIONS, CONTINGENT ASSETS AND CONTINGENT LIABILITIES|
|A brief description of the nature of the obligation. |
The carrying amount at the beginning and end of the previous year.
Additional provisions made during the previous year, including increases to existing provisions.
Amounts used, that is incurred and charged against the provision, during the previous year.
Unused amounts reversed during the previous year.
|6.||The amount of any expected reimbursement, stating the amount of any asset that has been recognised for that expected reimbursement.|
|7.||Following disclosure shall be made in respect of each class of asset and related income recognised as provided in para 11, namely:— |
· a brief description of the nature of the asset and related income;
· the carrying amount of asset at the beginning and end of the previous year;
· additional amount of asset and related income recognised during the year, including increases to assets and related income already recognised; and
· amount of asset and related income reversed during the previous year.
- Notes in case Income is being taxed on accrual basis irrespective of fact ICDS guides otherwise. For e.g. retention money, Interest on accrual etc.
- Taxpayer has adopted a position that retention money/interest income on non-performing asset /xxxx is not to be recognized as revenue since it does not become “due” to the taxpayer in absence of accrual conditions as per Section 5 being met. Reliance has been placed on judicial precedents like E.D. Sassoon & Co. Ltd. v CIT (1954) 26 ITR 27 (SC), CIT v Excel Industries Limited (2013) 358 ITR 295 (SC) and XXXXx. Accordingly, the total taxable income does not include the amount of said retention money/interest income on non-performing asset.
- If any clause is not applicable, rather than leaving it blank. “Not applicable” should be written.
- Appropriate management representation letter should be obtained from assesse.
- Disclosures needs to be suitable modified as per specific requirements