LETTER TO CBDT – NEW TAX AUDIT REPORT
(Mailed to chairman@incometaxindia.gov.in)
 

To,
 

The Chairman,
Central Board of Direct Taxes
New Delhi
 

Dear Sir, 
 

Re: - New Formats of Tax Audit Report in the Form 3CA, Form 3CB and Form 3CD.
 

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 through Notification No. 33/2014 dated 27/07/2014. 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. 

Sir, Please see here, that 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.

Respect Sir, 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 Sir, your Goodself has enormous talent and resources at your disposal but see, there is always delay in introduction of the ITRs for e-filing every year. The schema for Tax audit report was changed 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 and considering the ability of CBDT and its resourceful administration under your motivational leadership, 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.

Respected Sir, No doubt that your esteemed organization has 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 something is ready at our end we will introduce it suddenly and immediately” should be changed and Sir, what is newly introduced in Tax audit report are not very urgent matters which are required to be introduced in middle of the year suddenly and immediately.

Sir, there should not be a matter of secrecy in this respect, and sir, there are regulators of audit professions in our country in the form of ICAI (The Institute of Chartered Accountants of India) and before introduction of these type of matters which are directly related to audit, this organisation should also be consulted specially with respect to the time of applicability of new provisions instead of introducing the same in “sudden and immediate” manner. 

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. 

Further sir, since last 15 days, the schema of the TAR is not available on the e-filing site hence no audit report was uploaded and all these 15 days are practically wasted , your goodself is there requested to please extend the date by at least one month.

Thanking you

(We Request every Member to send letter/email to CBDT to Extend applicability of revised Tax Audit report to A.Y. 2015-16)

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