We have no news of release of TAR Utility Schema neither to postpone it so far, hampering tax audit work to a stand still all over India. No Tax audit is possible to be executed since 25th of July, due to CBDT unplanned Notification No. 33/2014 dtd 25.7.2014. This is height of our patience and causing undue hardship upon lakhs of Assessees and CAs in lack of proper planning at CBDT and wrong timing of said notification.

The insurance companies have requested to give TAR in new format and banks are in the offing to do so. Who will bear the huge cost of re-audit and travel again from branch to branch. If one has to certify only the TDS compliance of new TAR in case of banks, it would be a marathon task.

In between, the utility might be updated frequently by CBDT like past hampering the uploading and audit work in peak audit season. 

Now we have no remedy but to lodge our protest Effectively and Collectively, so as to make the proposed changes in TAR postponed to next AY as well as for the extension of due date of filing of audited ITRs with Existing TAR formats for AY 2014-15.

Time plays ultimate essence here, so we have to act fast. Once the Utility is launched by CBDT, it would be almost impossible to get its roll back.

Let us flood the mail boxes of CBDT, FM and DTC with thousands of mails by our representations. We should also submit its hard copy to CITs, local MPs and Media in every city all over the country by Tuesday to lodge our strong protest and make the mass aware about the status of working of CBDT making the life miserable of millions of assessee under tax audit and CA fraternity.

It's to be done Now or Never in the best interests of our clients, public and profession. Otherwise, we would have nothing, but to regret ever. The unethical practice of CBDT is to be checked immediately, else it would be a trend and routine for them in future.

A draft representation along with relevant mail-id's is followed by this mail/News. You are requested for its onward urgent submission to concerned and circulation among all your contacts. 

We request members to send letter/email to Chairman CBDT & CC to Finance Minister & Minister of State.

DRAFT LETTER/EMAIL PREPARED BY EXPERT PANNEL.

To, 

The Chairman,
Central Board of Direct Taxes,
New Delhi.

Dear Sir,

Re:-DEFERMENT OF New Audit Report To Assessment Year 2015-16.

Sir, the new format of tax audit report in Form No. 3CA, No. 3CB and No. 3CD through Notification No. 33/2014 dated 25/07/2014 were introduced on 25th July 2014 and are made applicable on the same day. In this respect we want to state some of the facts as under:-

1 AUDIT ALREADY COMPLETED BUT NOT UPLOADED:-.

The financial year preceding to the assessment year 2014-15 was ended on 31/03/2014 and audits for this year were started at any time after that date and completed before 25/07/2014 but the audit report are not uploaded on the IT site. Banks, Insurance Companies, PSUs and other assesses are included in this list. Now the auditors have to revisit them and collect the fresh information as incorporated in the new format.

2. FORMATS SHOULD BE INTRODUCED ON OR BEFRORE 31/03/2014

For assessment year 2014-15 the formats should be introduced before 31/03/2014 so that auditors can plan their work in advance and if there is an urgency and need to incorporate more information in the Format then the same should be planned in advance and if there is a delay in drafting, formation and introduction of the same then the very simple and reasonable solution is to make these formats applicable from the next assesseement year which in this case is Assessment year 2015-16.

3. ICAI HAS ALSO REQUESTED POSTPONEMENT

The Institute of chartered Accountants of India (ICAI) , established by an Act in Parliament , is the regulatory body for matters concerning the Audits in our Country and it appears from the representation moved by ICAI to the Hon. Finance Minister, Revenue Secretary and your good self , as mentioned on the website of ICAI www.icai.org that this apex body was not even consulted before midyear introduction of these formats since ICAI has also requested all the concerned authorities including your good self to postpone these formats for one year. Since the matter is connected with Audits hence the views of the ICAI should be given proper attention and respected.

4. NO SCHEMA SINCE LAST 23 DAYS

There are clear indications that the Midyear introduction of formats of audit report is not based on proper and basic preparation which is required and essential in this respect. The introduction was sudden but it is not explained anywhere that what is the urgency of such “sudden and midyear” introduction of these formats.

Sir since last 23 days there is no schema on the Income tax website with respect to these new formats of the audit report and this is the clear indication of the fact that it was introduced suddenly and without proper preparation. We are considered as the leading “Information Technology Nation” in the world and it is unbelievable for anybody to imagine that 23 days are not enough to prepare, test and introduce the schema for these formats. This is clear indication that there are “bottlenecks” in the system which has to be removed first and for this purpose planning and time is needed.

5. PLEASE REMEMBER 2013 CONFUSING EXPERIENCE

Sir, please take your time to prepare a proper schema and with proper schema introduce these formats and certainly this will take some more time. We have experience of changing and amending schema on weekly basis and sir this is not proper for the prestigious institution like CBDT. Here is the solution , please postpone these forms, consult ICAI for better and more practical format, prepare the schema , test it for bugs and debug it and make it foolproof and then make it applicable from assessment year 2015-16.

6. WHY TWO FORMATS FOR SAME ASSESSMENT YEAR

Since Some of the audit reports are already uploaded on the site of Income tax department before 25^th July 2014 hence now there are two types of assessees during the assessment year 2014-15 and the second set of assessees are those whose audit reports were not uploaded before 25^th July 2014 and here what is the logic to have two types of audit reports from different types of assessees in the same assessment year. The only reason of this “inequality” is that there are there are two sets of formats of audit reports in this particular assessment year 2014-15 due to this midyear introduction of Formats. The simple solution is that to postpone the New formats to assessment year 2015-16 and continue with the same (existed up to 25/07/2014) formats for all the assessees for the assessment year 2014-15.

7. GUIDANCE NOTE FROM ICAI- WILL TAKE IT’S OWN REQUIRED TIME

Sir, the audit work is not a “Mechanical work” and it requires expert knowledge, study and proper guidance from the ICAI (the apex body of auditors in India) and still “Guidance note” for the new formats for the audit report is not issued by the ICAI. Certainly this will require the consultation from the experts and it is also a task which will take its own time. The situation is created due to “sudden and midyear” introduction of the New formats and should certainly be avoided.

8. EXTEND THE TIME WITH EXISITING FORMATS- 2 MONTHS

Sir, the demand to defer the new formats to assessment year 2015-16 is a reasonable demand hence it is to be accepted by your good self as also demanded by ICAI but sir the whole exercise of this “midyear introduction” has created one more very serious problem which requires your immediate attention.

There is a confusion about applicability of the new formats because there is no schema on the web site of IT department since last 23 days and ICAI has also requested for its postponement to the assessment year 2015-16 hence the audit work and uploading the reports for assessment year 2014-15 has suffered seriously in all these 23 days and due to this loss of 23 days , more time is required to complete the audit in the existing formats (existed up to 25/07/2014) also hence your good self is requested to please extend the time up for uploading the audit report in existing formats (existed up to 25/07/2014) to 30/11/2014.

Thanking you

Yours faithfully

CC to:-

1._____________________________

2._____________________________

3._____________________________

4._____________________________

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