revised form 3cd presentation

Revised Form 3CD : CA Mehul Shah | 1

Revised Form 3CD

Amendments and Additions

CA MEHUL SHAH

RASESH SHAH AND ASSOCIATES

[email protected]

9723459572

International Taxation : CA Mehul Shah

Disclaimer

The stuff to follow are just “my opinion.” Opinion are like wrist watches. All show different times but all think that their time is correct…

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Amendment in Form No. 3CA, 3CB & 3CD

Notification No. 33/2014 dated 25th July, 2014

1. Form No. 3CA/3CB

a. Amendments in Form No. 3CAb. Amendments in Form No. 3CBc. Other amendments

2. Form No. 3CD

a. Newly inserted clausesb. Amendments in clausesc. Specific format provided


Amendments in Form 3CA

Scope of auditor increased :


Amendments in Form 3CB

Dispensed with Annexures to Form no 3CD and provided space for specifying observations and qualifications :


Amendments in Form 3CD : Overview


CLAUSE 4 - REGISTRATION NOS.

Clause

"Whether the assessee is liable to pay indirect tax like excise duty, service tax, sales tax, customs duty etc. if yes, please furnish the registration number or any other identification number allotted for the same"

Compliance

The auditor should obtain from the assessee and disclose the list of indirect taxes applicable to him as well as exercise his diligence regarding the applicability of different taxes based on the nature of the client business.

The aim of this clause would be to cross check the information like sales, production, CENVAT etc. submitted under various statutes.



Points to Remember

• Eventually, auditor is required to obtain a copy of the registration certificate clearly mentioning the registration number under that relevant law.

• Where the indirect tax law does not require any registration, appropriate

identification number may be reported in this clause. For example, in Customs Act, 1962, since there is no registration number, a copy of Export Import Code (IEC) may be obtained and information be accordingly furnished.



According to the Guidance Note ( ICAI) : The information may be obtained and maintained in the following format:


CLAUSE 8 - RELEVANT CLAUSE OF 44AB

Clause

"Indicate the relevant clause of section 44AB under which the audit has been conducted"

Compliance

To mention the relevant clause of 44AB :(a) Business(b) Profession (c) 44AE, 44BB, 44BBB (d) 44AD


CLAUSE 8 - RELEVANT CLAUSE OF 44AB

Clause

"Indicate the relevant clause of section 44AB under which the audit has been conducted"

Implications :

Section 194C and 194H etc only makes a reference to 44AB(a) and 44AB(b). Therefore, for individual & HUF, if audit is conducted u/s 44AB(c) & (d), TDS provisions are not applicable.


CLAUSE 11(b) - ADDRESS BOOKS

Clause

"List of books of account maintained and the address at which the books of accounts are kept. (If the books of accounts are not kept at one location, please furnish the addresses of locations along with the details of books of accounts maintained at each location. )"

Compliance

Disclosure of ‘Place of business’ regarding where the books are kept in order to facilitate a list of places where a visit could be initiated for conduct of ‘Survey’ under 133A.


CLAUSE 11(C) – RELEVANT DOCUMENTS

Clause

"List of books of account and nature of relevant documents examined."

Compliance

The auditor needs to disclose the list of ‘relevant documents’ examined which has a very wide scope including all Deeds, Agreements, Registrations, Returns, Challans, Invoices, BRS, Bank Statements, Salary Register, CENVAT Register etc.



Attention is also drawn to the definition of ‘document’ as per section2(22AA) of the Act which is as under:

"document" includes an electronic record as defined in clause (t) ofsub-section (1) of section 2 of the Information Technology Act, 2000

Section 2(1)(t) of the Information Technology Act, 2000 as referred above is reproduced below:

"electronic record" means data, record or data generated, image orsound stored, received or sent in an electronic form or micro film orcomputer generated micro fiche.



Books defined u/s 2(12A) - includes ledgers, day-books, cash books, account-books and other books.

The definition of term “document” and “books” is an inclusive definition and includes within its ambit documents other than those considered in definition- and hence very wide scope.


CLAUSE 17 - SALE OF IMMOVABLE PROPERTY

Clause

"Where any land or building or both is transferred during the previous year for a consideration less than value adopted or assessed or assessable by any authority of a State Government referred to in section 43CA or 50C, please furnish:

1. Details of property 2. Consideration received or accrued 3. Value adopted or assessed or assessable"

Compliance

The amount prevailing on the date of agreement has to be considered where any amount is received on or before the date of agreement. Reasonable checks should be applied by review of 26AS wherein TDS u/s 194IA has been deducted.



In the column requiring the details of property, the auditor has to furnish the

details about the nature of property i.e. whether the property transferred by

him is land or a building along with the address of such property. If the

assessee has transferred more than one property, the detail of all such

properties is required to be mentioned. The auditor should obtain a list of all

properties transferred by the assessee during the previous year. He may also

verify the same from the statement of profit and loss or balance sheet, as the

case may be. Attention is invited to the meaning of the term “transfer” as

defined in section 2(47) of the Act.



For reporting the value adopted or assessed or assessable, the auditor should

obtain from the assessee a copy of the registered sale deed in case, the

property is registered. In case the property is not registered, the auditor may

verify relevant documents from relevant authorities or obtain third party

expert like lawyer, solicitor representation to satisfy the compliance of section

43CA/ section 50C of the Act. In exceptional cases where the auditor is not

able to obtain relevant documents, he may state the same through an

observation in his report 3CA/CB.



Auditor would have to apply professional judgment as to what constitutes

land or building for e.g. whether leasehold right / development rights / TDR

etc would fall under this provisions or not, would require to be evaluated

based on facts & circumstances of transactions.


DCIT vs Tejinder Singh [ 32 CCH 58 (Kolkata Tribunal) ]

“monies received by the assessee being clearly in the nature of receipts for the

transfer of tenancy rights, section 50C of the act could not be invoked ”.



Issue

Can penalty be levied u/s 271(1) (c ) for addition u/s 43CA or 50C?


Renu Hingorani vs ACIT [ ITA No. 2210/Mum/2010 ]

“Merely because the assessee agreed for addition on the basis of valuation

made by the Stamp Valuation Authority would not be a conclusive proof that

the sale consideration as per this agreement was incorrect and wrong.

Accordingly the addition because of the deeming provisions does not ipso

facto attract the penalty u/s 271(1)(c ). Hence in view of the decision of the

Hon’ble Supreme Court in the case of CIT V/s Reliance Petroproducts Pvt.Ltd

(supra), the penalty levied u/s 271(1)( c ) is not sustainable. The same is

deleted. “


Sukhabhai P. Ahir (HUF) vs ITO [ITA No. 2454/Ahd/2009]

“ It is pertinent to note that in the quantum proceedings, there is no finding that

the assessee has received anything more than the consideration mentioned in

the sale deed. The addition was made by invoking the provisions contained in

section 50C of the I.T.Act, 1961. In the case of Shri Haresh P. Shah (supra),

relied on by the ld. Counsel of the assessee, on identical fact, the penalty of

Rs.33,082/- was levied under section 271(1)(c) of the I.T. Act and the same

was cancelled by the ITAT, ‘SMC’ Bench, Ahmedabad vide order dated

08.07.2010 (supra) and hence in the present case also the penalty is deleted “


CIT v/s. Madan Teatres Ltd 42 taxmann.com 26 (Cal HC)

“Assessee sold a property for a sum of Rs. 2.51 crore - For purpose of stamp

duty, value was estimated at a sum of Rs. 5.19 crore and on that basis stamp

duty was realized - Thereupon, Assessing Officer having adopted sale price at

Rs. 5.19 crore and passed a penalty order under section 271(1)(c) - Tribunal set

aside said penalty order - On appeal, it was noted that actual amount received

on sale was offered for taxation and it was only on basis of deemed

consideration proceedings under section 271(1)(c) were started - Even

otherwise, revenue failed to produce any iota of evidence that assessee actually

received one paise more than amount shown to have been received by him -

Whether in aforesaid circumstances, Tribunal was justified in setting aside

penalty order - Held, yes.”


CLAUSE 19 - DEDUCTIONS

Clause

“To provide the details of amounts debited vis-à-vis amounts admissible as per the provisions of the Income-tax Act, 1961 and also fulfil the conditions,

if any specified.”

Compliance

Admissibility of deductions under specific sections of the Income Tax Act, 1961 to be assessed and section wise chart to be given for deductions under additional sections of 33AB, 33ABA, 33AC , 35 , 35ABB, 35AC, 35CCA, 35CCB, 35D, 35DD, 35DDA,35E, 32AC, 35(2)(AB), 35AD, 35CCC, 35CCD.



Clause

“To provide the details of amounts debited vis-à-vis amounts admissible as per the provisions of the Income-tax Act, 1961 and also fulfil the conditions,

if any specified.”

Compliance

Admissibility of deductions under specific sections of the Income Tax Act, 1961 to be assessed and section wise chart to be given for deductions under additional sections of 33AB, 33ABA, 33AC , 35 , 35ABB, 35AC, 35CCA, 35CCB, 35D, 35DD, 35DDA,35E, 32AC, 35(2)(AB), 35AD, 35CCC, 35CCD.



The Tax Auditor should indicate the amount debited to the Profit &

Loss Account and the amount actually admissible in accordance with the

applicable provisions of law.

The amount not debited to the Profit & Loss Account but admissible

under any of the Sections mentioned in the clause have to be found out.


CLAUSE 20(b) – Employees’ Contribution

Clause

The clause requires the information regarding the various contributions made by employees to specific funds and deposited by the employer vvis-a-vis due date and actual date of such deposit in a tabular format.

Compliance


CLAUSE 20(b) – Employees’ Contribution

Issue :

Whether employees contribution allowable if paid after due date

mentioned in the relevant Act but before due date of filing return

of income.


CLAUSE 20(b) – Employees’ ContributionAny delayed deposit of employees’ contribution is deemed as income under

section 2(24)(x). The reporting has to be done under this clause irrespective

of the time of deposit. If the same has been deducted and deposited before the

due date of filing of return under section 139(1), then it is worthwhile to note

that the same may not be added to the income of the assessee as per following

judgements :

1) CIT vs AIMIL Ltd. [2010] 321 ITR 508 (Del)

2) CIT vs Kichha Sugar 356 ITR 351 (Utt)

However, a converse view has been taken in the case of CIT vs Gujarat

State Road Transport Corporation [2014] (41 Taxmann.com 100) by

Gujarat High Court.


CLAUSE 21(a) - INADMISSIBLE AMOUNTS

Clause 21(a)

"Please furnish the details of amounts debited to the profit and loss account, being in the nature of capital, personal, advertisement expenditure etc"

Sections covered by Clause 21(a):

Section 37(1) covers Personal or Capital Expenditure or Penalty

Section 37(2B) - advertisement in any souvenir, brochure, tract, pamphlet or the like published by a political party


CLAUSE 21(a) - INADMISSIBLE AMOUNTS

Where the penalty or fine is in the nature of penalty or fine only, the

entire amount thereof will have to be stated.

“In case of Malwa Vanaspati & Chemical Co. vs CIT [ 1997] 225 ITR 383

(SC), it was held that where the assessee is required to pay an amount

comprising both the elements of compensation and penalty, the amount shall

be bifercated and the compensation is allowable as business expenditure , and

penalty shall be disallowed”


CLAUSE 21 - INADMISSIBLE AMOUNTS

Clause 21(b):

"Amounts inadmissible under section 40(a):-

(1) as payment to non-resident referred to in sub-clause (i)

(A) Details of payment on which tax is not deducted: (B) Details of payment on which tax has been deducted but has not

been paid during the previous year or in the subsequent year before the expiry of time prescribed under section 200(1)"

Compliance

Date, amount, nature of payment, name & address of payee, amount of tax deducted.



Clause 21(b):

"Amounts inadmissible under section 40(a):-

(2) as payment referred to in sub-clause (ia)

(A) Details of payment on which tax is not deducted: (B) Details of payment on which tax has been deducted but has not

been paid on or before the due date specified in sub-section (1) of section 139."

Compliance

Date, amount, nature of payment, name & address of payee, amount of tax deducted.


CLAUSE 21(b) - INADMISSIBLE AMOUNTS

The Finance Act 2012, inserted second proviso in section 40(a)(ia) with

effect from 01-04-2013 (A.Y.2013-14) as a consequence to amendment in

Section 201. The second proviso provides that where an assessee fails to

deduct the whole or any part of the tax in accordance with the provisions of

Chapter XVII-B on any such sum but is not deemed to be an assessee in

default under the first proviso to sub-section (1) of section 201, then, for

the purpose of clause(ia) of section 40(a), it shall be deemed that the

assessee has deducted and paid the tax on such sum on the date of

furnishing of return of income by the resident payee referred to in the said

proviso.


CLAUSE 21(b) - INADMISSIBLE AMOUNTS

Where the auditee claims deduction under the second proviso to

subsection (ia) it is deemed that he has deducted and paid the tax

and hence such sum on which tax is so deemed to be deducted and

paid is not inadmissible, the tax auditor should verify compliance with

the requirements of section 201. He should also obtain and keep in

his record a copy of certificate in Form 26A as required by section 201

read with section 40(a)(ia).


CLAUSE 21(b) – Dineshkumar Deepakkumar Creation Pvt Ltd ( Ahmedabad Bench )

The amendment in 201 by Finance Act 2012 is retrospective in

nature.



Clause 21(d):

"Disallowance/deemed income under section 40A(3)”

Compliance

Serial No., Date, Nature, Amount of payment Name & PAN of the payee, if available.

Certificate now not to be obtained but CA should step in the shoes of the Assessing Officer.


CLAUSE 27(a) - CENVAT

Clause

"Amount of Central Value Added Tax credits availed of or utilised during the previous year and its treatment in the profit and loss account and treatment of outstanding Central Value Added Tax credits in the accounts."

Compliance

MODVAT replaced by CENVAT

Opening, Closing balance of CENVAT Credit Availed value and utilized value of CENVAT to be disclosed


CLAUSE 28 - 56(2)(viia)

Clause "Whether during the previous year the assessee has received any property, being share of a company not being a company in which the public are substantially interested, without consideration or for inadequate consideration as referred to in section 56(2)(viia), if yes, please furnish the details of the same."

Section 56(2)(viia) is applicable if following conditions are satisfied :-

1. Assessee is a Firm or a Company

2. Assessee receives Shares of another unlisted Company from any Person

3. The Shares are received without consideration or for a consideration less

than Fair market value of shares, so received

4. Aggregate FMV of shares so received is > Rs. 50,000/- in case of without

consideration or difference is > Rs. 50,000/- in case consideration is less than

FMV

Revised Form 3CD : CA Mehul Shah


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Compliance

FMV to be determined as per Rule 11U and 11UA. Section 56(2)(viia) shall not apply to transactions not regarded as transfer under section 47.

Said method is illustrated with an example.

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Basic exemption limit of Rs 50,000/- is not mentioned in Revised Form 3CD

though same is provided in section 56(2)(viia). Thus even if consideration

does not exceed basic exemption limit of Rs 50,000/- in aggregate, such

transaction of receipt of shares shall be reported in Revised Form 3CD.

However Tax Auditor may write a suitable Note that since the aggregate of

FMV or difference between consideration and FMV does not exceed Rs

50,000/-, it is not reported in Form 3CD as it does not have an impact on

Computation of Total Income.

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CLAUSE 29 - 56(2)(viib)

Clause

"Whether during the previous year the assessee received any consideration for issue of shares which exceeds the fair market value of the shares as referred to in section 56(2)(viib), if yes, please furnish the details of the same."

Section 56(2)(viib) is applicable if following conditions are satisfied :-1. Assessee is a Company2. Assessee receives consideration for the issue of its Shares from resident

person3. Shares are issued at a price which is higher than the Face value4. Aggregate consideration received exceeds the FMV of shares issued



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Compliance

Consideration received - FMV = Taxable i.e. excess share premium.

FMV = As determined under Rule 11U/UA or as substantiated to the satisfaction of the officer

Shall not apply to - Venture Capital Undertaking from Venture Capital Company/Venture Capital Fund or persons notified by Central Government.

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The proviso to section 68 added by Finance Act, 2012 and section

115BBE.

By making amendment in the proviso of this section now it will

be almost impossible to introduce unaccounted money in this

manner. In a way it is a very welcome amendment as it is to curb

introduction of black money in the guise of companies share

capital. In view of this now every company in which public are

not substantially interested shall have to maintain and in turn

produce before the Income tax authorities the genuineness and

creditworthiness besides the identity of the investors/shareholders

in share capital.

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The proviso to section 68 added by Finance Act, 2012 and section

115BBE.

With the amendment to section 68 by the Budget, 2012, in

respect of share capital and share premium, the insertion of

section 56(2)(viib) to treat the amount in excess of FMV as

income is not warranted. If we look through both the

amendments to section 56(2)(viib) and section 68, it is short of a

double jeopardy. The department should not resort to the new

provisions of section 56(2)(viib) if the source of amount in the

hands of shareholder/applicant of shares is satisfactorily proved

under section 68, as the new proviso to section 68 itself casts a

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The proviso to section 68 added by Finance Act, 2012 and section 115BBE.

duty. The law makers have not envisaged a situation where an

addition may be made under section 68 and if the shares are

issued at price more than FMV, the A.O. may also make deemed

addition under section 56(2)(viib). It is suggested that a proviso

should be added to section 56(2)(viib) to mitigate such hardship

by providing that the addition under section 56(2)(viib) will not

be made to the extent income is deemed under section 68 or vice

versa.

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The proviso to section 68 added by Finance Act, 2012 and section 115BBE.

As a result of amendment by the Budget, 2012, the tax rate for

amounts to be added under section 68 is now prescribed at

highest marginal rate under section 115BBE w.e.f. the assessment

year 2013-14.

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CLAUSE 32(d) - LOSS IN SPECIFIED BUSINESS

Clause

"whether the assessee has incurred any loss referred to in section 73A in respect of any specified business during the previous year, if yes, please furnish details of the same."

Compliance

35AD - specified businesses - loss to be reported.


CLAUSE 33 - CHAPTER III DEDUCTIONS

Clause

"Section-wise details of deductions, if any, admissible under Chapter VIA or Chapter III (Section 10A, Section 10AA)"


CLAUSE 33 - CHAPTER III DEDUCTIONS

Honourable Karnataka High Court dated 11.12.2013 in case of ACIT Vs. Motorola India Electronics.

The only difference is that Section 80HHC contains a further mandate in terms of Explanation (baa) for exclusion of certain income from the “profits of the business” which is, however, conspicuous by its absence in Section 10B. On the basis of the aforesaid distinction, Sub-section (4) of Section 10A/10B of the Act is a complete code by itself. Further, it is submitted that Sub-section (4) does not require an assessee to establish a direct nexus with the business of the undertaking and once an income forms part of the business of the undertaking, the same would be included in the profits of the business of the undertaking. Thus, once an income forms part of the business of the eligible undertaking, there is no further mandate in the provisions of section 10B to exclude the same from the eligible profits.


CLAUSE 34(a) - TDS/TCS CHART

Clause

"Whether the assessee is required to deduct or collect tax as per the provisions of Chapter XVII-B or Chapter XVII-BB, if yes please furnish"

Compliance

Tabular information of TDS/TCS

(i) TAN

(ii) Sections under which TDS or TCS deducted or collected

(iii) Nature of Payment

(iv) Total Amount of payment (including non-tax deductible or collectible portion)



(v) Total amount on which tax was to be deducted or collected

(vi) Total amount on which tax actually deducted or collected

(vii) Total amount of tax actually deducted or collected on above

(viii) Total amount on which tax actually deducted or collected at less than specified rate

(ix) Total amount of tax actually deducted or collected at less than specified rate

(x) Amount of tax deducted or collected but not deposited



Tax deduction and collection Account Number (TAN)

Section

Nature of payment

Total amount of payment or receipt of the nature specified in column (3)

Total amount on which tax was required to be deducted or collected out of (4)

Total amount on which tax was deducted or collected at specified rate out of (5)

Amount of tax deducted or collected out of (6)

Total amount on which tax was deducted or collected at less than specified rate out of (7)

Amount of tax deducted or collected on (8)

Amount of tax deducted or collected not deposited to the credit of the Central Government out of (6) and (8)

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

IT : When it was not established that there was failure on part of assessee to

disclose truly and correctly all material facts, assessment could not be reopened

after expiry of four years to disallow interest on ground that no interest was

offered on loan advanced and to disallow rent on ground that TDS was not

deducted thereon.

CIT vs Ankit Maheshwari [2014] 48 taxmann.com 147 (Gujarat)

PRICE WATERHOUSE COOPERS PVT. LTD. vs. CIT

Facts:

Penalty u/s 271(1)(c)—Assessee, by mistake claimed a deduction in

respect of provision towards payment of gratuity in its return of

income, even though Tax Audit Report indicated that such provision

was not allowable—AO initiated penalty on assessee for concealing

income.

Held:

Tax Audit Report was filed along with the return and that it unequivocally

stated that the provision for payment was not allowable under s 40A(7) of

the Act indicates that the assessee made a computation error in its return

of income. The contents of the Tax Audit Report suggest that there is no

question of the assessee concealing its income. There is also no question of

the assessee furnishing any inaccurate particulars. It appears that all that

has happened in the present case is that through a bona fide and

inadvertent error, the assessee while submitting its return, failed to add

the provision for gratuity to its total income….

PRICE WATERHOUSE COOPERS PVT. LTD. VS. CIT

Held:

… Cont

This can only be described as a human error which we are all prone to

make. The calibre and expertise of the assessee has little or nothing to

do with the inadvertent error. That the assessee should have been

careful cannot be doubted, but the absence of due care, in a case such

as the present, does not mean that the assessee is guilty of either

furnishing inaccurate particulars or attempting to conceal its income.

PRICE WATERHOUSE COOPERS PVT. LTD. VS. CIT


CLAUSE 34(b) - LATE FILING OF TDS RETURN

Clause

“Whether the assessee has furnished the statement of tax deducted or tax collected within the prescribed time. If not, please furnish the details"

Compliance

To provide details of whether TDS return has been filed on time or not.If TDS/TCS return is filed late entire late filed return will have to be verified since the clause requires following details:

"Whether the statement of tax deducted or collected contains information about all transactions which are required to be reported"


CLAUSE 34(c) - INTEREST - TDS/TCS

Clause "whether the assessee is liable to pay interest under section 201(1A) or section 206C(7). If yes, please furnish:

(i) TAN

(ii) Amount of interest payable

(iii) Amount paid out of (ii) mentioned above

(iv) Date of payment"

Compliance

Auditor will have to recheck calculation of the interest on default in

payments of TDS/TCS. Also need to cross check from 26AS.


CLAUSE 37 & 38 - COST AUDIT & Excise Audit

Clause 37

"Whether any cost audit was carried out, if yes, give the details, if any, of disqualification or disagreement on any matter /item/ value/ quantity as may be reported/ identified by the cost auditor."

Clause 38

"Whether any audit was conducted under the Central Excise Act,1944, if yes, give the details, if any, of disqualification or disagreement on any matter /item /value /quantity as may be reported/identified by the auditor."


CLAUSE 39 - SERVICE TAX AUDIT

Clause

"Whether any audit was conducted under section 72A of the Finance Act, 1994 in relation to valuation of taxable services, if yes, give the details, if any, of disqualification or disagreement on any matter/item/ value/ quantity as may be reported/identified by the auditor."


CLAUSE 40 - RATIOS

Clause

"Details regarding turnover, gross profit, etc., for the previous year and preceding previous year:"

Compliance

Comparative data of previous year to be reported.

Total turnover is to be reported for the previous year as well as for preceding financial year.


CLAUSE 41 - DEMAND OR REFUND UNDER ANY TAX LAWS

Clause

"Please furnish the details of demand raised or refund issued during the previous year under any tax laws other than Income tax Act, 1961 and Wealth tax Act, 1957 along with details of relevant proceedings."

Compliance

If the details are not available from the client, relevant disclosures to be made in Form 3CA/ Form 3CB


REMOVAL OF ANNEXURE I

Annexure removed.


QUESTIONS FROM THE AUDIENCE


In case of query ,

72

CA Mehul Shah

Mobile : 9723459572

E-mail : [email protected]

Partner

Rasesh Shah and Assocaites

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mailto:[email protected]

International Taxation : CA Mehul Shah | 73


ABOUT THE AUTHOR

Author, Mr. Mehul Rasesh Shah is a member of the ICAI. He has pursued

certificate Course in International Taxation in the year 2012 conducted by the

ICAI. He has also completed his Diploma in IFRS (ACCA, London) and Advanced

Diploma in Management Accounting (CIMA, London) in the year 2013. Currently

he is handling many Appellate proceedings including representation before the

Tribunal and Settlement Commission. He can be reached at [email protected]

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