Excel for Chartered Accountants
The following attachments are required for each of the form:
30-07-2013 | CA Ashutosh Lohani |
As we all are aware that for Assessment Year 2013-14 and onwards various audit reports under section 10(23C), section 10, section 10A, section 12A, section 44AB, section 80-IA, section 80-IB, section 80-IC, section 80-ID, section 80JJA, section 80LA, section 92E or section 115JB of Income Tax Act, 1961 are required to be filed electronically.
What are the attachments required to be submitted?
Instructions given for attachments:
There seems to be some ambiguity in specifying the format and size limit of attachments.
Now, the point of ambiguity is with respect of:
What is the right format for a valid attachment?
Till the time a clarification is made by the Income Tax Department , in my opinion the following formats could qualify to be used for attachments:
Let us remember that as per Information Technology Act, 2000, any document which has been digitally signed has the same legal validity as physically signed document, provided it has been signed via a Digital Signature Certificate issued by a licensed Certifying Authority. The very preamble of the Act together with section together with its sections makes it very clear.
1. Attachment in MS Word or MS Excel formats signed digitally and zipped
Microsoft Word 2007 and Microsoft Excel 2007 both do have abilities to add digital signatures to it. However the zip format as
How to Add Signatures to Word or Excel 2007?
2. Attachment in PDF formats signed digitally.
In view of the provisions of Information Technology Act as described above and acceptability of pdf format as per instructions give,
Note that one should not attempt to convert digitally signed MS Word 2007 or MS Excel 2007 into pdf formats. The converted pdf
Instead, Adobe Acrobat software should be used to edit any converted pdf files to add signature to it. It should be noted that that
Adobe Acrobat Standard XI software which is priced at Rs. 20638/- can be used to add digital signatures to any pdf file. The price
3. Attachment of scanned documents not signed digitally
This is another but cumbersome method that can be used to scan the images of the physically sign documents with minimum 300
To many, this is the only valid way for uploading the attachments.
4. Attachment of unsigned PDF documents with Sd/- marking
We have an example of MCA allowing Sd/ written unsigned copies of the documents including financial statements. The ground
Therefore pending any clarification by Income tax Department, I would suggest the second and third methods out of four listed above for uploading attachments to Form 3CA or Form 3CD. A request for clarification has already been filed with Dirctor I. Tax (Systems) under RTI Act. Application filed under RTI and replies received so far.
10-09-2013 : ICAI FAQ on e-filing of Tax Audit Report
Now ICAI has come up with a
FAQ on efiling of Tax Audit Report
.It is a welcome step. However as per FAQ it has been stated that it has been
by Direct Taxes Committee of ICAI in consultation with the Officials of Directorate of Income-Tax (Systems). Para 3 of the FAQ states that Balance Sheet, Profit and Loss Account in Word, Excel Format, etc signed as "sd/-" can be converted in to pdf file and uploaded on the portal. It is notable that Directorate of Income-Tax (Systems) replying under RTI has expressed as having no information with resepect to many questions on e-filing of Tax Audit report. Further, the FAQ hosted by ICAI is not appearing at Income Tax Website. Under these circumstances who would take the responsibility if an Income tax official later on issues notice of penalty treating such sd/ wriiten financial statements as non furnishing of audit report as required under section 44AB?