FORM 3CD – Statement of Particulars of Tax Audit

FORM 3CD – Statement of Particulars of Tax Audit

FORM 3CD

Statement of Particulars

Form No. 3CD is the format in which the statement of particulars of tax audit is required to be furnished. This form has a total of 44 clauses where the auditor has to report on various matters contained therein. These clauses have been divided into two parts – Part A covers the basic factual details about the assessee and Part B contains the particulars of various compliances under the income tax laws that need to be furnished

So let’s start a discussion in these 44 clauses –

PART – A

Clause 1: Name

Give the name of the assessee whose accounts are being audited under section 44AB along with the name of the branch or proprietory firm or company as the case may be. Also if there is the change in the name of the entity then the fact should be disclosed. In case of any change in the name of the assessee between the last day of the previous year and the date of tax audit report, the name as on the last date of the previous year and also on the tax audit report date be stated.

Clause 2: Address

The address should be the address of the assessee which he is using for the communication/notices etc send by the department may be taken as effective service, address as appearing on Tax Challans, PAN, etc along with the name of the branch or proprietory firm or company as the case may be. In case of a change in address after the end of the financial year and before the date of a tax audit, the fact should be disclosed. In case of a change in address after the end of the financial year and before the date of the tax audit, the fact may be brought on form 3CD.The address of the registered office is stated along with the principal place of business, if any in the case of the company

FORM 3CD – Statement of Particulars of Tax Audit

Clause 3: Permanent Account Number ( PAN ) of the assessee

Give the PAN of the assessee. If the pan number is not allotted as on the date of signing of the audit report, the fact should be disclosed. If the PAN has been applied and the same has not been allotted for, it is advisable to seek a copy of pan application acknowledgment.

Clause 4: Details as to Indirect tax registration

The registration numbers with the respective tax authorities need to be entered in this clause

Clause 5: Status

The status does not refer to the residential status. It means the status of the person who is defined as per section 2(31) i.e Individual, HUF, Company, Firm, etc. In case there is any dispute with respect to the status of the assessee, full facts relating to the same should be mentioned.

Clause 6: Previous year ( PY ) ended

Here the date of which the previous year ended has to be stated. Since presently the previous year u/s 3 of The Income Tax Act are uniform and ends on 31st March, being a financial year, the relevant previous year should be mentioned.

Clause 7: Assessment year ( AY ) ended

Here the assessment year relevant to the previous year whose accounts are being audited should be stated.

Clause 8: Indicate the relevant clause of section 44AB under which the audit has been conducted

In this, we have to choose from the relevant clauses in section 44AB i.e.

A. In case the assessee is carrying on business and his total sales, turnover or gross receipts as the case may be, exceeds one crore in the relevant previous year.
B. If the assessee is carrying on the profession and his gross receipts exceed twenty-five lakh rupees in the relevant previous year.
C. If the audit under section 44AB is being conducted under provisions of section 44AE, 44BB and 44BBB
D. For audit being conducted under provisions of section 44ADA
E. For audit being conducted under provisions of section 44AD

PART – B

Clause 9: Particulars of Partners/members of firm or AOP, their P.S.R and changes

A. If firm or Association of Persons, indicate names of partners/members and their profit-sharing ratios.

B. If there is any change in the partners or members or in their profit sharing ratio since the last date of the preceding year, the particulars of such change.

Clause 10: Nature of business/change

A. Nature of business or profession ( If there is more than one business and profession is carried on during the PY, than the nature of every business or profession should be reported

B. If there is any change in the nature of business or profession, the particulars of such change.

Clause 11: Books of account prescribed, maintained, and examined.

A. Whether books of account are prescribed under section 44AA, if yes, list of books so prescribed.

Section 44AA – Every person carrying on any business or a profession (other than professions referred in Rule 6F), are required to maintain such books of account and other documents, as may enable the Assessing Officer to compute his total income, in following cases

1. If his total income from business or profession exceeds 2,50,000 for Individual or HUF or his total sales/gross receipts from such business or profession exceeds Rs.25,00,000 for Individual or HUF in any of the three years immediately preceding the relevant previous year.

2. In case of newly set of business or profession, the assessee will be required to maintain accounts if, during the relevant accounting year, either his total income is likely to exceed Rs.2,50,000 for Individual or HUF or the total sales or gross receipts are likely to exceed Rs.25,00,000 for Individual or HUF.

3. If he is carrying on any business covered u/s 44AE, 44BB or 44BBB and Claims his income to be Lower than the presumptive profit computed under the said sections during the previous year.

4. If the provisions of section 44AD(4) are applicable and his income exceeds the maximum amount not chargeable to tax in any previous year.

B. Lists of books of account maintained and the address at which the books of account are kept.

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

Clause 12: Whether the profit or loss account includes any profits and gains assessable on a presumptive basis, if yes, indicate the amount and the relevant section (44AD, 44AE, 44AF, 44B, 44BB, 44BBA, 44BBB, Chapter XII-G, First Schedule or any other relevant section)

Obtain an analysis of revenues and ascertain whether the profit and gains arising from such revenues are assessable on a presumptive basis for the following:

• 44AD – business profit on estimated basis
• 44AE – business of plying, hiring or leasing goods carriages
• 44AF – retail Business
• 44BB – business of exploration at mineral oils.
• 44BBA – operation of Aircraft by non-resident
• 44BBB – Foreign companies engaged in civil construction etc. in turnkey power projects
• 44B – Special provision for computing profits and gains of shipping business in the case of non-residents
• Chapter XII-G – Special provisions relating to Shipping Companies (Section 115V to 115VT)
• First Schedule – Insurance Business

Clause 13: Books of Accounts and ICDS

A. Method of accounting employed in the previous year.

B. Whether there had been any change in the method of accounting employed vis-a-vis the method employed in the immediately preceding previous year.

C. If the answer to (b) above is in the affirmative, give details of such change, and the effect thereof on the profit or loss.

S No.	Particulars	Increase in Profits	Decrease in Profits

The method of accounting, whether cash or mercantile must be mentioned. And please report in clause 12(b) if there is a change in method of accounting and kindly disclose the effect from such change in clause 12(c)

D. Whether any adjustment is required to be made to the profits or loss for complying with the provisions of income computation and disclosure standards notified under section 145(2).

E. If the answer to (d) above is in the affirmative, give details of such adjustments

F. Disclosure as per ICDS

Not all ICDS are required to be disclosed as per Income Tax Act only 8 are required to be disclosed.

Clause 14: Closing Stock

A. Method of valuation of closing stock employed in the previous year.

Mention method of valuation of stock i.e. LIFO, FIFO, WAM etc.

B. Details of deviation, if any, from the method of valuation prescribed under section 145A, and the effect thereof on the profit or loss.

Be consistent with the method of valuation of stock but if changed then effect of such should be disclosed in clause 13(b).

Section 145A provides that the valuation of purchase and sale of goods and inventory for the purpose of computation of income from business or profession shall be made on the basis of the method of accounting REGULARLY employed by the assessee but this shall be subject to certain adjustments.

Therefore, it is NOT necessary to change the method of valuation of purchase, sale and inventory regularly employed in the books of account.

(a) Any tax, duty, cess or fee actually paid or incurred on inputs should be ADDED to the cost of inputs (raw-materials, stores etc.); if not already added in the books of account.

(b) Any tax, duty, cess or fee actually paid or incurred on sale of goods should be ADDED to the sales, if

(c) Any tax, duty, cess or fee actually paid or incurred on the inventory (finished goods, work-in-progress, raw materials etc.) should be ADDED to the inventories, if not already added while valuing the not already added in the books of account inventory in the accounts.

Clause 15: Conversion of Capital asset into stock in trade

A. Description of capital asset

Description of the capital asset is required to be mentioned for example shares, security, land, building, plant machinery etc.

B. Date of acquisition

For ascertaining the correct date we have to refer the accounts of the financial year in which such capital asset in acquired. It is important to determine the asset is long-term or short term in nature

C. Cost of acquisition

The cost of acquisition as per the books of account is to be mentioned. In case of deducible assets, the carrying cost appearing in the books will be the written down value

D. Amount at which the asset is converted into stock-in- trade

The amount recorded in the books of account at which the asset is converted into stock image should be stated.

Clause 16: Chargeability of PGBP

Amounts not credited to the profit and loss account, being,-

A. the items falling within the scope of section 28;
B. the proforma credits, drawbacks, refund of duty of customs or excise or
C. service tax, or refund of sales tax or value added tax, where such credits,
D. drawbacks or refunds are admitted as due by the authorities concerned;
E. escalation claims accepted during the previous year; for the Contractors
F. any other item of income;
G. capital receipt, if any i.e. capital subsidy received in form of govt. grants, government grants received in respect of specific fixed assets, compensation for surrendering certain rights, profits on sale of fixed assets/ investments.

Section 28 is the charging section for the income under the head ‘profits and gains of business or profession’. This clause intends to capture and report those incomes which ordinarily wouldn’t be a business income but is deemed to be business income by virtue of the Income Tax Act. Even export benefits like pro forma credits, duty drawbacks, refund of customs, etc. would be covered under this clause if not credited to the profit and loss account. Further, a capital receipt would not normally attract tax unless the transaction is specifically covered in the provisions. Thus if such receipt is not appearing in the profit and loss account it will be covered here.

Clause 17: Where any land or building or both is transferred during the previous year for a consideration less than value adopted or assesseed or assessable by any authority of a State Government referred to in section 43CA or 50 please furnish:

Sec 50C: Section 50C is applicable only to land or building or both. Section 50C uses value adopted by the Stamp Valuation Authority (SVA) for the purpose of levying stamp duty on registration of properties, as guidance value to determine undervaluation of land or building if any in the sale agreement. In case sale consideration received or claimed to be received by seller on sale of land or building or both is less than value adopted by stamp valuation authority, such value adopted by SVA would become actual sale consideration received or accruing to the seller. Therefore, capital gain would be Valuation as per stamp valuation authority reduced by cost/indexed cost of acquisition.

However, budget 2018 has brought about an amendment in section 50C whereby no adjustments shall be made in a case where the variation between stamp duty value and the sale consideration is not more than five percent of the sale consideration. This has been introduced in order to minimize hardship in case of genuine transactions in the real estate sector.

Sec 43CA:

Where the consideration received or accruing as a result of the transfer by an assessee of an asset (other than a capital asset), being land or building or both, is less than the value adopted or assesseed or assessable by any authority of a State Government for the purpose of payment of stamp duty in respect of such transfer, the value so adopted or assesseed or assessable shall, for the purposes of computing profits and gains from transfer of such asset, be deemed to be the full value of the consideration received or accruing as a result of such transfer.

Clause 18: Particulars of depreciation allowable as per the Income Tax Act, 1961 in respect of each asset or block of asset, as the case may be, in the following form:-

A. Depreciation of asset/block of assets

B. Rate of depreciation

C. The actual cost of written down value, as the case may be

D. Additions/deductions during the year with dates; in the case of any addition of an asset, date put to use; including adjustment on account of:

(i) Central Value Added Tax credits claimed and allowed under the Central Excise Rules, 1944, in respect of assets acquired on or after 1st March 1994,

(ii) change in rate of currency, and

(iii) subsidy or grant or reimbursement, by whatever name called.

E. Depreciation allowable

F. Written down value at the end of the year – Closing WDV

Clause 19: Amounts admissible under sections: 32AC, 32AD, 33AB, 33ABA, 35(1)(i), 35(1)(ii), 35(1)(iia), 35(1)(iii), 35(1)(iv), 35(2AA), 35(2AB), 35ABB, 35AC, 35AD, 35CCA, 35CCB, 35CCC, 35CCD, 35D, 35DD, 35DDA, 35E;

In this clause we have to simply disclose the amount debited in profit & loss and the amount admissable in respect of those transactions under various sections.

Clause 20: Employee profits and contribution to funds

A. Any sum paid to an employee as bonus or commission for services rendered, where such sum was otherwise payable to him as profits or dividend

The assessee would be allowed a deduction in respect of a payment made to an employee in the nature of a bonus of commission only if such bonus or commission was available exclusively to such an employee in relation to the services rendered by him.

B. Details of contribution received from employees for various funds as referred to in section 36(1)(va)

These funds include superannuation funds created for the benefit of the employee. The contributions made by the employer to such funds shall be allowed as a deduction only if they are made within the due date as specified in the applicable law i.e. 15th of the next month.

Clause 21: Amount Debited to Profit & Loss Account

Any sum paid to an employee as bonus or commission for services rendered, where such sum was otherwise payable to him as profits or dividend. [Section 36(1)(ii)]

The nature of these expenses is such that they may either be fully disallowed or only allowed subject to certain conditions. If they form a part of the profit and loss account, they have to be disclosed here.

(b) Amounts inadmissible under section 40(a):-

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

(A) Details of payment on which tax is not deducted:

(I) date of payment…………………….

(II) amount of payment…………………….

(III) nature of payment…………………….

(IV) name and address of the payee…………………….

(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 the time prescribed under section 200(1)

(I) date of payment…………………….

(II) amount of payment…………………….

(III) nature of payment…………………….

(IV) name and address of the payee…………………….

(V) amount of tax deducted…………………….

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

(A) Details of payment on which tax is not deducted:

(I) date of payment…………………….

(II) amount of payment…………………….

(III) nature of payment…………………….

(IV) name and address of the payee…………………….

(B) Details of payment on which tax has been deducted but has not been paid on or before the due date specified in subsection (1) of section 139.

(I) date of payment…………………….

(II) amount of payment…………………….

(III) nature of payment…………………….

(IV) name and address of the payer*…………………….

(V) amount of tax deducted…………………….

(VI) amount out of (V) deposited if any …………………….

(iii) under sub-clause (ic) [Wherever applicable]………….

(iv) under sub-clause (iia) …………………….

(v) under sub-clause (iib) …………………….

(vi) under sub-clause (iii)

(A) date of payment …………………….

(B) amount of payment …………………….

(C) name and address of the payee …………………….

(vii) under sub-clause (iv) …………………….

These sections broadly relate to disallowances made in respect of an expenditure or a part of an expenditure where tax was required to be deducted at source but the assessee failed to do so.

• U/s 40(a)(i) – Any interest, royalty, fees for technical services or other sums chargeable under the Income-tax Act which is payable outside India or in India to a non-resident or a foreign company on which tax is deductible at source and such tax has not been deducted
• U/s 40(a)(ia) – Any interest, commission or brokerage, rent, royalty, fees for professional services or fees for technical services payable to a resident or amounts payable to a contractor or subcontractor, being resident, for carrying out any work, on which TDS is deductible and such tax has not been deducted.
• U/s 40(a)(ic) – Fringe Benefit Tax
• U/s 40(a)(iia) – Wealth Tax
• U/s 40(a)(iib) – Any amount paid by way of a Royalty, License Fees, Service Fees, Privilege Fees, Service Charges or any other fees
• U/s 40(a)(iii) – Any payment towards ‘Salaries’, if it is payable outside India; or to a nonresident.
• U/s 40(a)(iv) – Any payment to a provident or other fund established for the benefit of employees of the assessee.
• U/s 40(a)(v) – Any tax actually paid by an employer referred to in clause (10CC) of section 10.

(c) Amounts debited to profit and loss account being, interest, salary, bonus, commission or remuneration inadmissible under section 40(b)/40(ba) and computation thereof;…………………….

This is applicable to firm, AOP or BOI assessees where payments are made to the partners/members in the nature of salary, remuneration, interest, etc. The Act has prescribed certain limits up to which such expenditure can be allowed in the hands of the firm/AOP/BOI and if the expenditure exceeds this limit, the same is not allowed as a deduction.

(d) Disallowance/deemed income under section 40A(3):

(A) On the basis of the examination of books of account and other relevant documents/evidence, whether the expenditure covered under section 40A(3) read with rule 6DD was made by account payee cheque drawn on a bank or account payee bank draft. If not, please furnish the details:

(B) On the basis of the examination of books of account and other relevant documents/evidence, whether the payment referred to in section 40A(3A) read with rule 6DD were made by account payee cheque drawn on a bank or account payee bank draft If not, please furnish the details of the amount deemed to be the profits and gains of business or profession under section 40A(3A);

Disallowance on expenditure incurred by any mode other than an cheque/bank draft or through a bank account using ECS if they exceed Rs. 10,000 in a day subject to certain exceptions.

(e) provision for payment of gratuity not allowable under section 40A(7); …………………….

The tax auditor should verify the Details of the provision made for gratuity but not paid would be disallowed u/s 40A(7) and is to be disclosed under this clause from the assessee, the order of the Commissioner of Income-tax granting approval to the gratuity fund, verify the date from which it is effective and also verify whether the provision has been made as provided in the trust deed. If the assessee has not provided or made a contribution to the approved Gratuity fund, then the Tax Auditor needs to verify the reporting in this clause.

(f) any sum paid by the assessee as an employer not allowable under section 40A(9); …………………….

Section 40A(9) disallows expenditure incurred on setting up or formation of or as a contribution to, any fund, trust, company, an association of persons, the body of individuals, a society registered under the Societies Registration Act, 1860

(g) particulars of any liability of a contingent nature; …………………….

Such a liability usually relates to ongoing legal disputes where it is not certain that there will be a liability for the as assessee.

(h) amount of deduction inadmissible in terms of section 14A in respect of the expenditure incurred in relation to income which does not form part of the total income; …………………….

The section prescribes a method of calculation of an amount of expenditure which will be disallowed as it is deemed to be incurred towards earning exempt income.

(i) amount inadmissible under the proviso to section 36(1)(iii). …………………….

The said provision was amended by Finance Act 2015 and is in line with ICDS IX (Borrowing Costs), where the interest paid in respect of the amount borrowed for purpose of business is not allowed till the date asset was first put to use. The Tax Auditor while reporting under this sub-clause should refer to the Accounting Policy adopted by the assessee in this regard. He should evaluate whether the Accounting Policy is in line with principles laid down in AS-16.

Clause 22: Amount of interest inadmissible under section 23 of the Micro, Small and Medium Enterprises Development Act, 2006.

The principal amount and interest due thereon (to be shown separately) remaining unpaid to any supplier as at the end of each accounting year.

Clause 23: Particulars of payments made to persons specified under section 40A(2)(b).

• Individual including Relatives of lineal ascendant or descendant
• All assessees i.e. company, firm, HUF, AOP, etc.
• Director(s) of the company, partners in a firm, association members or family or relative of people in HUF.

Clause 24: Amounts deemed to be profits and gains under section 32AC or 32AD or 33AB or 33ABA or 33AC.

These sections allow for a special deduction to certain assessees subject to certain conditions. In case of a breach of these conditions, the whole or a part of the deduction allowed earlier would be included as deemed income

Sec-32AC:

Under this new section 32AC, a manufacturing company is entitled to an investment allowance @ 15% of actual cost of new plant and machinery acquired and installed during the financial years 2013-14 and 2014-15, if the actual cost of new plant and machinery exceeds Rs.100 Crore. Section 32AC allows a deduction for investment in new plant and machinery. This deduction is allowed in addition to the depreciation and additional depreciation.

Sec-32AD:

Every assessee setting up an undertaking for manufacture or production of any article on or after 01/04/2015 in any notified backwards areas of Andhra Pradesh, Bihar, Telangana, West Bengal are eligible for deduction in case investment is made in new plant and machinery.

Sec-33AB:

Under Section 33AB of the Income Tax Act 1961, the tea producers are allowed a deduction upto 20 per cent of their profits provided the amounts are deposited with Nabard within six months of the previous year.

Sec-33ABA:

Applicable to an assessee carrying on business, consisting of prospecting or extraction or production of petroleum or natural gas or both, in India, in respect of which the Central Govt. has entered into an agreement with the assessee

Sec-33AC:

In case of an assessee, being a Government company or a public company formed and registered in India with the main object of carrying on the business of operation of ships, there shall, in accordance with and subject to the provisions of this section, be allowed a deduction of an amount not exceeding fifty percent of profits derived from the business of operations of ships, as is debited to profit and loss account of the previous year in respect of which the deduction is to be allowed and credited to a reserve account.

Clause 25: Any amount of profit chargeable to tax under section 41 and computation thereof.

This section relates to deemed profits arising out of:

• Recovery against any Allowance or Deduction Allowed earlier
• Where an asset has been sold by an assessee engaged in the power generation and distribution and such sale consideration exceeds the written down value.
• Sale of Scientific Research Asset
• Bad debt recovered
• Amount is withdrawn from Special Reserve Created and Maintained by certain Financial
• Where sun amount is received after Discontinuance of Business or Profession

Clause 26: In respect of any sum referred to in clauses (a), (b), (c), (d), (e), (f) or (g) of section 43B, the liability for which:-

A. In respect of any sum referred to in clauses (a), (b), (c), (d), (e), (f) or (g) of section 43B, the liability for which preceding previous year and was

a. paid during the previous year; …………………….

b. not paid during the previous year; …………………….

B. was incurred in the previous year and was

a. paid on or before the due date for furnishing the return of income of the previous year under section 139(1); …………………….
b. not paid on or before the aforesaid date. …………………….
(State whether sales tax, customs duty, excise duty or any other indirect tax, levy, cess, impost, etc., is passed through the profit and loss account.)

Sec 43B: In the computation of income under the head Profits and gains of business or profession (PGBP), some of the expenses are allowed under Income Tax Act 1961 and can be claimed by the assessee only in the year in which the payment is actually made.

a. Any tax, duty, cess or fee paid under any law in force is allowed as a deduction when it is paid

b. Contribution to any recognized employee’s benefit fund: contribution by the employer to any employee’s benefit fund

c. Bonus or commission payable to employees

d. Interest on borrowings from Public Financial Institutions or State Financial Corporation in accordance with the conditions governing such loan

e. Interest on loans and advances from Scheduled Bank in accordance with the conditions governing such loan

f. Leave encashment provided by an employer to his employee

g. Payment to Indian Railways

Clause 27: CENVAT Credit

a. 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. …………………….

The details of the CENVAT credit carried forward from the previous year, its utilization and the balance left needs to be provided along with the treatment of the same in the accounts of the as assessee.

b. Particulars of income or expenditure of prior period credited or debited to the profit and loss account.

This clause would be relevant only for the persons following the mercantile system of accounting.

Clause 28: 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 details of the same.

Reporting obligation under clause 28 is triggered if the following conditions are satisfied:

a) assessee is a firm or LLP or a closely held company; and
b) assessee receives shares of a closely held company during the previous year; and
c) Such shares are received without consideration or for inadequate consideration

If the above conditions are not fulfilled, then tax auditor shall simply state “No” against clause 28. If the above conditions are fulfilled, the tax auditor shall state “Yes” against clause 28 and also furnish details of shares so received.

Clause 28 does not specify what details are to be furnished. It is suggested that the details may be furnished in a format provided in e-filing utility tabulated as under:

Clause 29: 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. …………………….

29A. (a) Whether any amount is to be included as income chargeable under the head ‘income from other sources’ as referred to in clause (ix) of sub-section (2) of section 56? (Yes/No)

(b) If yes, please furnish the following details:

(i) Nature of income:

(ii) Amount thereof:

It is to provide for taxability of any sum received as an advance or otherwise in the course of negotiations for transfer of capital asset. Since it is a capital receipt it was earlier allowed as a deduction from the cost of acquisition. The same is now taxed as a revenue receipt in the year of receipt under the head IOS. Making it taxable in the year of receipt is a good move and in the interest of the revenue. However, the other side of the same transaction also needs consideration i.e. from the payer’s point of view whose money has been forfeited. Since the receipt is deemed to be revenue due to the enactment, it follows that the expenses in the hands of the payer would also be revenue in nature. Consequently, corresponding benefit needs to be provided to the payer.

29B. (a) Whether any amount is to be included as income chargeable under the head ‘income from other sources’ as referred to in clause (x) of sub-section (2) of section 56? (Yes/No)

(b) If yes, please furnish the following details:

(i) Nature of income:

Gift is usually used to convert black money into white money. To stop practice of converting black money into white money a section 56(2)(Vii) introduced by Finance Act , 2009 and amended by Finance act , 2010. This section deals with law of taxation of gift.

Clause 30: Details of any amount borrowed on hundi or any amount due thereon (including interest on the amount borrowed) repaid, otherwise than through an account payee cheque. [Section 69D]

The auditors should Obtain a complete list of borrowings and repayments of hundi loans otherwise than by account payee cheques and verify the same with the books of account. It also includes reporting of the name of the name of the parties involved, date, the amount, and other particulars may be given. The e-filing portal gives the format in which the details are to be given. Check the bank book and bank statement too.

Clause 30A: a) Whether primary adjustment to transfer price, as referred to in sub-section 1) of section 92CE, has been made during the previous year? (Yes/No)

(b) If yes, please furnish the following details:—

(i) Under which clause of sub-section (1) of section 92CE primary adjustment is made?

(ii) Amount of primary adjustment:

(iii) Whether the excess money available with the associated enterprise is required to be repatriated to India as per the provisions of sub-section (2) of section 92CE? (Yes/No)

(iv) If yes, whether the excess money has been repatriated within the prescribed time (Yes/No)

(v) If no, the amount of imputed interest income on such excess money which has not been repatriated within the prescribed time:

The transfer pricing provisions under the Income Tax Act in general aim to value transactions with associated enterprises at an arm’s length price. This clause aims to capture such relevant information within the tax audit report.

A primary adjustment is the difference between the transfer price determined based on the arm’s-length principle and the transfer price at which the transaction took place. This difference also represents the ‘excess money’ with the AE that is required to be repatriated to India.

A “secondary adjustment” has been defined to mean an adjustment in the books of accounts of the taxpayer and its AE to reflect that the actual allocation of profits between the taxpayer and its AE are consistent with the transfer price determined as a result of the primary adjustment.

Clause 30B: (a) Whether the assessee has incurred expenditure during the previos year by way of interest or of similar nature exceeding one crore rupees as referred to in sub-section (1) of section 94B? (Yes/No.)

(b) If yes, please furnish the following details:—

(i) Amount of expenditure by way of interest or of similar nature incurred:

(ii) Earnings before interest, tax, depreciation and amortization (EBITDA) during the previous year

(iii) Amount of expenditure by way interest or of similar nature as per (i) above which exceeds 30% of EBITDA as per (ii) above:

(iv) Details of interest expenditure brought forward as per sub-section (4) of section 94B:

(v) Details of interest expenditure carried forward as per sub-section (4) of section 94B:

Where an Indian Company borrows a sum of money from an associated enterprise, the deduction in respect of interest payable on such borrowed amount under the Income-tax Act shall be restricted to 30% of EBITDA . The interest in excess of 30% shall be allowed to be set off in subsequent years subject to certain conditions. This clause places a check for compliance in this regard.

Clause 30C: (a) Whether the assessee has entered into an impermissible avoidance arrangement, as referred to in section 96, during the previous year? (Yes/No.)

(b) If yes, please specify:—

(i) Nature of impermissible avoidance arrangement:

(ii) Amount of tax benefit in the previous year arising, in aggregate, to all the parties to the arrangement:

An impermissible avoidance arrangement would be an arrangement where the main purpose is to obtain a tax benefit and is not at arm’s length, results in tax evasion (directly or indirectly), lacks commercial substance or is carried out in a manner that does not otherwise occur if the arrangement was for bona fide purposes.

Clause 31: (a) Particulars of each loan or deposit in an amount exceeding the limit specified in section 269SS taken or accepted during the previous year: —

(i) name, address and Permanent Account Number or Aadhaar Number (if available with the assessee) of the lender or depositor;

(ii) amount of loan or deposit taken or accepted;

(iii) whether the loan or deposit was squared up during the previous year;

(iv) maximum amount outstanding in the account at any time during the previous year;

(v) whether the loan or deposit was taken or accepted by cheque or bank draft or use of electronic clearing system through a bank account;

(vi) in case the loan or deposit was taken or accepted by cheque or bank draft, whether the same was taken or accepted by an account payee cheque or an account payee bank draft.

As per section 269SS, A person cannot accept loan or deposit or any other specified sum from another person otherwise than by an account payee cheque or account payee bank draft or use of electronic clearing system through a bank account, if, Amount of loan or deposit or specified sum is Rs. 20,000 or more, or Sum total amount of loan, deposit, and the specified sum is Rs. 20,000 or more.

(b) Particulars of each specified sum in an amount exceeding the limit specified in section 269SS taken or accepted during the previous year: —

(i) name, address and Permanent Account Number or Aadhaar Number (if available with the assessee) of the person from whom the specified sum is received;

(ii) amount of specified sum taken or accepted;

(iii) whether the specified sum was taken or accepted by cheque or bank draft or use of electronic clearing system through a bank account;

(iv) in case the specified sum was taken or accepted by cheque or bank draft, whether the same was taken or accepted by an account payee cheque or an account payee bank draft.

(Particulars at (a) and (b) need not be given in the case of a Government company, a banking company or a corporation established by the Central, State or Provincial Act.)

The auditor needs to take care of the following for this sub-clause:

• Not only advance but any sum received in relation to transfer of immovable property (including payment received at the time of sale) is covered under this clause.
• He should scrutinize all the accounts in which the assessee had taken or accepted any specified sum mentioned above during the year.
• If the specified sum is accepted by cheque or bank draft whether these are Account payee or not is to be reported.

(ba) Particulars of each receipt in an amount exceeding the limit specified in section 269ST, in aggregate from a person in a day or in respect of a single transaction or in respect of transactions relating to one event or occasion from a person, during the previous year, where such receipt is otherwise than by a cheque or bank draft or use of electronic clearing system through a bank account:—

(i) Name, address and Permanent Account Number or Aadhaar Number (if available with the assessee) of the payer;

(ii) Nature of transaction;

(iii) Amount of receipt ;

(iv) Date of receipt;

The auditor needs to Verify the cash book to determine whether cash is received of Rs. 2 lakhs or more in a single day to a person.

He can also Obtain a management representation from the assessee that it did not receive any amount of Rs. 2 Lakhs or more otherwise than by cheque, draft or ECS for any of the following:

• in the aggregate to a person in a day; or
• in respect of a single transaction; or
• in respect of transactions relating to one event or occasion to a person

(bb) Particulars of each receipt in an amount exceeding the limit specified in section 269ST, in aggregate from a person in a day or in respect of a single transaction or in respect of transactions relating to one event or occasions from a person, received by a cheque or bank draft, not being an account payee cheque or an account payee bank draft, during the previous year;—

(i) Name, address and Permanent Account Number or Aadhaar Number (if available with the assessee) of the payer;

(ii) Amount of receipt ;

Section 269ST says that a person is not allowed to receive more than Rs. 2 lakh but If such amount is paid through any mode other than an account payee cheque / bank draft or use of ECS through a bank account. The reporting of non-compliance with this section will be made in this clause.

(bc) Particulars of each payment made in an amount exceeding the limit specified in section 269ST, in aggregate to a person in a day or in respect of a single transaction or in respect of transactions relating to one event or occasions to a person, otherwise than by a cheque or bank draft, or use of electronic clearing system through a bank account, during the previous year:—

(i) Name, address and Permanent Account Number or Aadhaar Number (if available with the assessee) of the payee;

(ii) Nature of transaction;

(iii) Amount of payment (in Rs.);

(iv) Date of payment;

The auditor needs to Verify the cash book , the ledgers and other documents to determine whether cash is paid of Rs. 2 lakhs or more in a single day to a person.

He can also Obtain a management representation from the assessee that it did not pay any amount of Rs. 2 Lakhs or more other-wise than by cheque, draft or ECS for any of the following:

• in the aggregate to a person in a day; or
• in respect of a single transaction; or
• in respect of transactions relating to one event or occasion to a person

(bd) Particulars of each payment made in an amount exceeding the limit specified in section 269ST, in the aggregate to a person in a day or in respect of a single transaction or in respect of transactions relating to one event or occasions to a person, made by a cheque or bank draft, not being an account payee cheque or an account payee bank draft, during the previous year:—

(i) Name, address and Permanent Account Number or Aadhaar Number (if available with the assessee) of the payee;

(ii) Amount of payment ;

(Particulars at (ba), (bb), (bc) and (bd) need not be given in the case of receipt by or payment to a Government company, a banking Company, a post office savings bank, a cooperative bank or in the case of transactions referred to in section 269SS or in the case of persons referred to in Notification No. S.O. 2065(E) dated 3rd July, 2017)

It requires to report only in case when the above mentioned payment is made by cheque or bank draft and the cheque or bank draft was not an account payee cheque or account payee bank draft. There could be practical difficulties in verifying that the amount in question has been paid by account payee cheque or an account payee bank draft. In such cases, the tax auditor should verify the transactions with reference to such evidence which may be available and report in Form 3CA/3CB

(c) Particulars of each repayment of loan or deposit or any specified advance in an amount exceeding the limit specified in section 269T made during the previous year:—

(i) name, address and Permanent Account Number or Aadhaar Number (if available with the assessee) of the payee;

(ii) amount of the repayment;

(iii) maximum amount outstanding in the account at any time during the previous year;

(iv) whether the repayment was made by cheque or bank draft or use of electronic clearing system through a bank account;

(v) in case the repayment was made by cheque or bank draft, whether the same was repaid by an account payee cheque or an account payee bank draft.

Section 269T prohibits any person to repay the loan or deposit or specified sum otherwise than by an account payee cheque or account payee bank draft or by use of electronic clearing system through a bank account, if Amount of loan or deposit, including interest amount, is Rs. 20,000 or more, or The aggregate amount of loans or deposits, including the interest amount, held by such person in his own name, or jointly with any person, is Rs. 20,000 or more.

(d) Particulars of repayment of loan or deposit or any specified advance in an amount exceeding the limit specified in section 269T received otherwise than by a cheque or bank draft or use of electronic clearing system through a bank account during the previous year:—

(i) name, address and Permanent Account Number or Aadhaar Number (if available with the assessee) of the payer*;

(ii) repayment of loan or deposit or any specified advance received otherwise than by a cheque or bank draft or use of electronic clearing system through a bank account during the previous year.

This clause is for reporting of PAYMENT RECEIVED of LOAN / DEPOSIT / SPECIFIED ADVANCE in contravention of s. 269T. There is no penalty on the assessee u/s 271F for payment received, as the same is only on the payer, yet this information is sought by the department to take appropriate action on the payer. If the loan / deposit / specified advance given is received back otherwise than by cheque or bank draft or ECS, the same is to be reported under this clause.

In simple terms if a person want to repay loan / deposit / specified advance then it is not allowed to pay in cash more than 20000 as specified in law so we have to report in this clause for the same.

(e) Particulars of repayment of loan or deposit or any specified advance in an amount exceeding the limit specified in section 269T received by a cheque or bank draft which is not an account payee cheque or account payee bank draft during the previous year:—

i) name, address and Permanent Account Number or Aadhaar Number (if available with the assessee) of the payer*;

(ii) repayment of loan or deposit or any specified advance received by a cheque or a bank draft which is not an account payee cheque or account payee bank draft during the previous year.

(Particulars at (c), (d) and (e) need not be given in the case of a repayment of any loan or deposit or any specified advance taken or accepted from the Government, Government company, banking company or a corporation established by the Central, State or Provincial Act).

It requires reporting only in case when the above mentioned payment is received by cheque or bank draft and the cheque or bank draft was not an account payee cheque or accounting payee bank draft. There could be practical difficulties in verifying that the amount in question has been received by account payee cheque or an account payee bank draft. In such cases, the tax auditor should verify the transactions with reference to such evidence which may be available and report in Form 3CA/3CB.

Clause 32: Set off & Carryforward

A. Details of brought forward loss or depreciation allowance, in the following manner, to the extent available:

Brought forward losses may pertain to different heads of income such as property income, profits and gains in business or profession, speculation business or capital gains, the provisions of which are contained in sections 32 and 70 to 79.

Such amounts need to be revised for any change arising out of a rectification order, assessment order, etc.

Any assessment, rectification, revision or appeal proceedings pending at the time of tax audit have to be disclosed under remarks column under sub-clause (a). If orders are yet to be passed, the same can be disclosed along with impact thereof, if the material

B. Whether a change in shareholding of the company has taken place in the previous year due to which the losses incurred prior to the previous year cannot be allowed to be carried forward in terms of section 79.

Sec 79: Notwithstanding anything contained in this Chapter, where a change in shareholding has taken place during the previous year in the case of a company, not being a company in which the public are substantially interested, no loss incurred in any year prior to the previous year shall be carried forward and set off against the income of the previous year, unless on the last day of the previous year, the shares of the company carrying not less than fifty-one percent of the voting power were beneficially held by persons who beneficially held shares of the company carrying not less than fifty-one percent of the voting power on the last day of the year or years in which the loss was incurred.

C. Whether the assessee has incurred any speculation loss referred to in section 73 during the previous year, If yes, please furnish the details of the same.

Section 73 – provides that any loss in respect of speculation business shall not be set off except against profits or gains of another speculation business

D. 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.

Section 73A – provides that Any loss, computed in respect of any specified business referred to in section 35AD shall not be set off except against profits and gains, if any, of any other specified business.

E. In case of a company, please state that whether the company is deemed to be carrying on a speculation business as referred in explanation to section 73, if yes, please furnish the details of speculation loss if any incurred during the previous year.

A transaction of purchase or sale of a commodity including stocks and shares settled otherwise than by actual delivery or transfer of the commodity or scrip is a speculative transaction. The business which consists of speculative transactions is called as speculative business.

A speculation loss cannot be set off against any income other than a speculation gain. Further, a loss in speculation business will be allowed to be carried forward for only 4 years. This clause keeps the above provisions in check.

Clause 33: Section-wise details of deductions, if any, admissible under Chapter VIA or Chapter III (Section 10A, Section 10AA).

The tax auditor will have to verify whether the assessee has fulfilled the conditions necessary to claim the section-wise deductions.

Sec 10A:

It seeks to promote and boost new business undertakings situated in free trade zones by providing suitable deductions. It provides for a 100 percent deduction of profits and gains derived by undertakings engaged in the export of articles or computer software. The deduction is available for ten assessment years from the year in which the entity commences operations. These profits are to be determined based on the ratio of export turnover to the total turnover of the undertaking.

Sec 10AA:

It is introduced with a view to attracting foreign investment in India, the Government announced that tax concessions would be provided for entrepreneurs who set up the specified businesses in Special Economic Zones. Accordingly, initially, SEZs were instituted to function under the provisions of the Foreign Trade Policy. However, gradually, the SEZ Act and SEZ rules were formed and made effective from the year 2006. Income tax benefit or Section 10AA deduction is available to SEZ and the corresponding provisions are contained under section 10AA of the Income Tax Act. The present article highlights the various conditions for claiming the deduction under Section 10AA, the amount of income tax benefit/deduction available under the section, and other salient features of the section.

Clause 34: TDS / TCS

(a) 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:

The Auditor need to report section-wise details of TDS/TCS deducted/collected and paid.The auditor should obtain a copy of the TDS/TCS statements filed by the assessee which shall form the basis of reporting under this clause, to the extent possible. In case an assessee has the voluminous nature of the transactions, the auditor may apply test checks and compliance tests on the transactions reported in the TDS statements by the assessee for verifying the information required to be provided under this clause.

(b) whether the assessee is required to furnish the statement of tax deducted or tax collected. If yes, please furnish the details:

The auditor has to ascertain and report as to whether the assessee is required to furnish the TDS / TCS Statement. The requirement was to report under this clause only when the statements were filed late.

Auditors have to report on-

a) TAN of the assessee.

b) Type of Form – All Forms have to be reported in this clause i.e., Form 24, 24G, 24Q, 26, 26A, 26B, 26Q etc,

c) Due Date for furnishing.

d) Actual Date of furnishing the return (if furnished) – Date of original return being furnished should be stated, even if the statement is revised / corrected later.

e) It could be difficult for the auditor to verify each and every transaction in this regard. Therefore, while verifying such transactions, he can apply the concepts of materiality and audit sampling.

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

Section 201(1A) provides for payment of interest at a specified rate in case the tax has not been deducted wholly or partly or after deducting has not been paid to the credit of Central Government. Similarly, section 206C(7) provides for payment of interest at a specified rate in case the tax is not collected wholly or partly or if collected not paid to the credit of the Central Government. Where the assessee is liable to pay interest u/s 201(1A) or 206C(7),the auditor should verify such amount from the books of account as on 31st March of the relevant previous year and also from the statement generated by the IT Department in Form No. 26AS.

Clause 35: Details regarding Stock

(a) In the case of a trading concern, give quantitative details of principal items of goods traded:

(i) Opening Stock; …………………….

(ii) purchases during the previous year; …………………….

(iii) sales during the previous year; …………………….

(iv) closing stock; …………………….

(v) shortage/excess, if any …………………….

(b) In the case of a manufacturing concern, give quantitative details of the principal items of raw materials, finished products and by-products:

A. Raw Materials:

(i) opening stock; …………………….

(ii) purchases during the previous year; …………………….

(iii) consumption during the previous year; …………………….

(iv) sales during the previous year; …………………….

(v) closing stock; …………………….

(vi) yield of finished products; …………………….

(vii) percentage of yield; …………………….

(viii) shortage/excess, if any. …………………….

Auditor should obtain certificates from the assessee in respect of the principal items of goods traded, the balance of opening stock, purchases, sales and closing stock and the extent of shortage/excess/damage and the reasons for the same. Principal items here would mean the items which constitute more than 10% of the aggregate value of purchases or sales.

B. Finished products/by-products:

(i) opening stock; …………………….

(ii) purchases during the previous year; …………………….

(iii) quantity manufactured during the previous year; …………………….

(iv) sales during the previous year; …………………….

(v) closing stock; …………………….

(vi) shortage/excess, if any. …………………….

Auditor should check the details of purchase, consumption and production of principal items of raw materials and finished goods. The auditor should obtain the following certified documents for principal items of raw materials, finished products and by-products:

• Certificate from the assessee certifying the quantity and value of the opening stock, purchases, sales and closing stock.
• Certificate to the extent of shortage/excess/damage and the reasons for the same.

The details are required only in case of assessee being traders or manufacturers. This clause is not applicable to service providers.

Clause 36: In the case of a domestic company, details of tax on distributed profits under section 115-O in the following form:-

(a) total amount of distributed profits; …………………….

(b) amount of reduction as referred to in section 115-O (1A)(i); …………………….

(c) amount of reduction as referred to in section 115-O (1A)(ii); …………………….

(d) total tax paid thereon; …………………….

(e) dates of payment with amounts. …………………….

Section 115-O(1) – provides for levy of tax on dividends paid. This is irrespective of whether dividend is paid out of current profits or accumulated profits. It is in addition to the income-tax chargeable of a domestic company for any assessment year

Section 115-O(1A) – The amount referred to in sub-section (1) shall be reduced by,—

(i) the amount of dividend, if any, received by the domestic company during the financial year, if such dividend is received from its subsidiary and,—

b. where such subsidiary is a domestic company, the subsidiary has paid the tax which is payable under this section on such dividend; or

c. where such subsidiary is a foreign company, the tax is payable by the domestic company under section 115BBD on such dividend:

(ii) the amount of dividend, if any, paid to any person for, or on behalf of, the New Pension System Trust referred to in clause (44) of section 10.

36A. (a) Whether the assesee has received any amount in the nature of dividend as referred to in sub clause (e) of clause (22) of section 2? (Yes/No.)

The assessee could not provide appropriate information / details to determine accumulated profits to enable us to report that the loan / advance received by the assessee is deemed dividend or not u/s 2(22)(e).

(b) If yes, please furnish the following details:—

(i) Amount received:

(ii) Date of receipt:

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.

The tax auditor has to state if cost audit was carried out and if the answer is in affirmative, he has to attach the copy of the same. The tax auditor is not required to make detailed study of the cost audit report however he has to take note of any material observation having relevance to tax audit. Where the cost audit has been ordered but is not completed by the time of tax audit report, the fact relating to same is to be stated. Information is required to be given only in respect of such cost audit whose time period corresponds to the previous year under tax audit.

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.

The tax auditor has to state if any audit was conducted under the Central Excise Act. 1944 and if the answer is in affirmative, he has to attach the copy of the same. The tax auditor is not required to make detailed study of such audit report however he has to take note of any material observation having relevance to tax audit. Where the audit has been ordered under central excise but is not completed by the time of tax audit report, the fact relating to same is to be stated. Information is required to be given only in respect of such excise audit whose time period corresponds to the previous year under tax audit.

Clause 39: 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.

Section 72A of the Finance Act, 1994 has been introduced with a view to provide for a special audit to be carried out by a CA or cost accountant nominated by the Commissioner. The special audit shall be ordered where the service tax assessee has failed to declare or determine the value of taxable service or has availed and utilized credit of duty or tax beyond the normal limit or by means of, collusion or willful misstatement or he is having operations spread out in multiple locations.

It is further proposed to provide that the CA or as the case may be, the cost accountant shall submit a report to the Commissioner on completion of the audit and such audit may be ordered even though such accounts had been audited under any other law for the time being in force. Before initiating proceedings on the basis of the report, a reasonable opportunity of being heard shall be given to the service tax assessee so audited.

Clause 40: Details regarding turnover, gross profit, etc., for the previous year and preceding previous year:

( The details required to be furnished for principal items of goods traded or manufactured or services Rendered )

Calculation of such ratios would not be applicable for persons engaged in profession/ service industry. The net profit to be shown is NPBT. In case of partnership firm the NP ratio has to be calculated after charging interest and remuneration to partners. The stock turnover ratio is to be computed while taking only finished goods.

Clause 41: 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 alongwith details of relevant proceedings.

This clause has been inserted from Assessment Year: 2014-15

1. Central Excise Duty
2. Service Tax
3. Customs Duty
4. Value Added Tax
5. Central Sales Tax
6. Professional Tax

Disclosure which are to be reported under this clause:

a) Demand/Refund order issued during the previous year.

It may be noted that demand/refund of a period other than the relevant previous year also to be included.

b) Any adjustment of the refund against demand raised, such instances are also to be reported under this clause.

Clause 42: (a) Whether the assessee is required to furnish statement in Form No.61 or Form No.61A or Form 61B? (Yes/No)

Form 61 should be submitted by an individual whose income is only obtained by agricultural department or from any employment and who does not earn any kind of income taxable unless inferred from the transaction mentioned in the a-h clauses under the law of 114b. This Form is published by the Income Tax Department of India under the jurisdiction of Central Board of Direct Taxes.

For keeping a watch on the high-value transactions done by the taxpayers, the Income Tax Act has framed a new concept to furnish a Statement of Financial Transactions in a prescribed Form 61A also known as AIR (Annual Information Return) previously. In other words, the Statement of Financial Transactions or Form 61A is a record of specified financial transactions that should be furnished under the Income Tax Act.

Requirement of filing Form 61B arises for implementation of FATCA (Foreign Account Tax Compliance Act) and CRS (Common Reporting Standard). For this purpose rule 114F, 114G and 114H are to be referred. Briefly, these rules provide for due diligence procedure for identification of reportable accounts. Once a Reporting Entity identifies reportable accounts, information about such accounts is to be filed in form 61B for the calendar year by 31st of May following the end of the calendar year

(b) If yes, please furnish:

Clause 43: (a) Whether the assessee or its parent entity or alternate reporting entity is liable to furnish the report as referred to in sub-section (2) of section 286? (Yes/No)

In reference to above section 286 (2) states:

Every parent entity or the alternate reporting entity, resident in India, shall, for every reporting accounting year, in respect of the international group of which it is a constituent, furnish a report, to the prescribed authority within a period of twelve months from the end of the said reporting accounting year, in the form and manner as may be prescribed.

(b) If yes, please furnish the following details:

(i) Whether report has been furnished by the assessee or its parent entity or an alternate reporting entity

(ii) Name of parent entity

(iii) Name of alternate reporting entity (if applicable)

(iv) Date of furnishing of report

Clause 44: Break-up of the total expenditure of entities registered or not registered under the GST:

In this clause, we have to furnish all details to GST authorities regarding the breakup of expenditure. Information is to be given irrespective of the fact that you are registered or unregistered under GST law.

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This Article is written by VISHAL ARYA.

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