E FilingofvariousauditreportsunderIncomeTax

e-Filing of audit report
under Income Tax Act,

1961
CA. Deepak Bholusaria
[email protected]
Background
Assessee deliberately did not disclose some or all

adverse remarks of Tax Audit Report.
Assessee didnt disallow some expenses, even if they

were disallowed by tax auditor.
Since Return of Income (ROI) did not contain tax audit

report, it was not possible for department to trace such
instances.
Many assessees used fake CA membership number, in

his/its ROI. Even in many cases CA membership
number of part-time COP Holder were also reported.
Goal and Objective
Understanding key requirements for e-filing

of audit reports.
Understanding types of audit reports which

are not available for e-filing.
Discussion on flow of process and

understanding each process thoroughly,
along with demo on each process.
Challenges and solutions.
Tips and tricks.
Checklist
Compatible operating system (XP/SP3, Win7/8

etc.)
Compatible Web browser (IE/Chrome/FireFox)
Internet connectivity
Java Min. Ver should be JRE 1.7 update 13
Offline report preparation software to generate

XML file for respective audit report
Financial statements and other documents are

signed and scanned
Valid digital signatures of auditor and assessee
Access credentials to e-filing portal
Type of various forms

(other than ITR)
available for e-filing
Proviso to rule 12(2)*

Provided that where an assessee is required to furnish a
report of audit specified under:
sub-clauses (iv), (v), (vi) or (via) of clause (23C) of section
10,
section 10A,
clause (b) of sub-section (1) of section 12A,
section 44AB,
section 80-IA, section 80-IB, section 80-IC, section 80-ID,
section 80JJAA,
section 80LA,
section 92E or
section 115JB of the Act
he shall furnish the same electronically.
No Audit report u/s 115JC is required to be e-filed
Total e-filing forms
other than ITR - as on August 7, 2013

Total*
Mandatory
Optional
45
11
34
Total*
Offline
Online
45
40
Total*
Initiated
by CA
Initiated by
Assessee
Both
45
19
25
* Form 3CA-3CD / 3CB-3CD counted as one form
Mandatory e-Audit reports
as per proviso to rule 12(2) For AY 2013-14

Relevant Section / clause
Specified Audit Report Form No.
44AB
3CA-3CD or 3CB-3CD
12A(1)(b)
10B
10(23C)(iv)/(v)/(vi)/(via)
10BB
10A
56F
80-IA / 80-IC
10CCB
80-IB
10CCBD
80-ID
10CCBBA
80JJAA
10DA
80LA
10CCF
92E
3CEB
115JB
29B
Red coloured forms are online forms
What about audit reports for

44AD / 44AE / 44BB / 4BBB?
Reports for audits conducted under section 44AD

or 44AE or 44BB or 44BBB are mandatorily
required to be furnished electronically.
Audits conducted under Section 44AD & 44AE of

the Income Tax Act, 1961 shall not be taken into
account for the purpose of reckoning the
specified number of tax audit assignments as per
guidelines* of ICAI.
*There is no reference to section 44BB/44BBB in ICAI guidelines
Report u/s section 115JC
Report in form no. 29C u/s 115JC of

Income Tax Act, 1961 is not at all
available for e-filing either under online
format or offline format.
Trusts required to obtain

report in 10B/10BB
Reports in form no. 10B/10BB are

mandatorily required to be furnished
electronically.
Process Flow
(for forms initiated by CA)
Process flow
1. Register as Tax
Professional
Chartered
Accountant
Filling Complete
2. Auditor ask
assessee to add
him/her using Add
CA option.
3. Auditor has to
Download offline
utility and prepare
XML file.
5. Assessee login
to portal accept
filing. In case of
rejection, auditor
to repeat step 4.
4. Auditor login to
portal and upload
digitally signed
XML file and
attachments.
Registration of
Auditor
Registration Tax professional
Only Chartered Accountants holding full time

active COP can register.
No firm can be registered as Tax

Professional.
Only an Individual CA can register. All

signing partners from a firm of Chartered
accountants have to separately take
registration.

Basic info required for registration of CA:
a.
Six digit membership number
b.
Date of Enrolment as member of ICAI
c.
PAN
d.
Name (as per PAN data)
e.
DoB
f.
PAN Based digital signature
(should be same as per ICAI and ITD)

User id will be like this:
ARCA 999999
First 4 alphabets are fixed ARCA

Next 6 digits Your ICAI MRN
In case you forget your password it can be

retrieved using forgot password option.
Registration screen
Process flow
1. Register as Tax
Professional
Chartered
Accountant
Filling Complete
2. Auditor ask
assessee to add
him/her using Add
CA option.
3. Auditor has to
Download offline
utility and prepare
XML file.
5. Assessee login
to portal accept
filing. In case of
rejection, auditor
to repeat step 4.
4. Auditor login to
portal and upload
digitally signed
XML file and
attachments.
Adding CA
Adding CA
Akin to appointment of auditor (This will not replace

standard procedure of obtaining formal appointment
letter from assessee).
Before any auditor can upload digitally signed XML

file of audit report, he has to seek authorisation from
assessee.
Assessee logins to portal using his PAN based

access credentials and authorise CA for a particular
form and assessment year.
This is a one time exercise to be done by assessee

every year.
Adding CA
Before an assessee can exercise Add CA option,

an auditor (as Individual, not as firm) must be
already registered on E-filing portal as Tax
Professional
Auditors Tax Professional user id must be active.
Assessee may authorise one CA for more than 1

form for a particular assessment year in one go, if
that CA has been appointed for all such audits (Eg.,
3CB+3CEB+29B etc.)
Only one CA can be added for a particular form and

assessment year.
Adding CA Multiple Auditors

Q: What if an assessee has multiple
divisions/businesses and has appointed multiple
tax auditors for different divisions/businesses?
A: In opinion of presenter/speaker, assessee shall have
to appoint one tax auditor for the purpose of
consolidated tax audit report. Such an auditor can
either be from the pool of auditors already appointed for
various divisions or additional auditor may be
appointed.
In opinion of presenter/speaker, in case of joint auditors
also, assessee may nominate one of the joint auditors
for the purpose of e-filing of audit report.
Adding CA Signing Member

Assessee has to add membership number of that
particular Tax Auditor, who has signed/will sign its
financial statements.
Even in cases where a firm of CA has been appointed
as tax auditor, only the CA who has signed audit report
on behalf of firm of CA has to be added.
One member can not upload report on behalf of another
member, even if another member is his partner.
Only the signing member can upload report, since XML
files have to digitally signed.
Can CA be changed?
Yes!
To change CA, either of two options are available to

assessee:
a.
He can simply use Add CA option and add

membership number of new CA and select Yes
when portal ask for replacement; or
b.
First go to Dis-engage CA sub-menu option in My

Account menu, select CA to be removed and press
Dis-engage button. Post that, use Add CA option
to add new CA.
Process flow
1. Register as Tax
Professional
Chartered
Accountant
Filling Complete
2. Auditor ask
assessee to add
him/her using Add
CA option.
3. Auditor has to
Download offline
utility and prepare
XML file.
5. Assessee login
to portal accept
filing. In case of
rejection, auditor
to repeat step 4.
4. Auditor login to
portal and upload
digitally signed
XML file and
attachments.
Process flow
1. Register as Tax
Professional
Chartered
Accountant
Filling Complete
2. Auditor ask
assessee to add
him/her using Add
CA option.
3. Auditor has to
Download offline
utility and prepare
XML file.
5. Assessee login
to portal accept
filing. In case of
rejection, auditor
to repeat step 4.
4. Auditor login to
portal and upload
digitally signed
XML file and
attachments.
Login and Upload
Technical requirements
(offline mode)
Balance Sheet (or Statement of Affairs) and profit &

loss account (or Income & Expenditure account) to be
mandatorily attached with form 3CA/3CB or form
10BB, as the case may be.
Cost audit report / excise report will also be a

mandatory attachment depending upon tax auditors
answer in form 3CD.
No option for multiple attachments of a single set of

document.
All attachments to be signed and scanned
Attachments to be in pdf/tiff format
Technical requirements
(offline mode)
Total of all 4 attachments can not exceed 20MB Fair

Size (there is a conflict on this at various sections of
portal)
There is no option to upload and store attachments on

portal.
If due to any reason (connectivity etc.) link to portal is

disconnected entire attachments to be uploaded again.
XML file has to comply with latest Schema notified by ITD

irrespective of preparation utility used.
Only CA who has signed audit report has to login and

upload
User ID of the CA must be active at the time of upload
Process flow
1. Register as Tax
Professional
Chartered
Accountant
Filling Complete
2. Auditor ask
assessee to add
him/her using Add
CA option.
3. Auditor has to
Download offline
utility and prepare
XML file.
5. Assessee login
to portal accept
filing. In case of
rejection, auditor
to repeat step 4.
4. Auditor login to
portal and upload
digitally signed
XML file and
attachments.
Process flow
1. Register as Tax
Professional
Chartered
Accountant
Filling Complete
2. Auditor ask
assessee to add
him/her using Add
CA option.
3. Auditor has to
Download offline
utility and prepare
XML file.
5. Assessee login
to portal accept
filing. In case of
rejection, auditor
to repeat step 4.
4. Auditor login to
portal and upload
digitally signed
XML file and
attachments.
General FAQs
Will portal accept more than

45 Tax Audit reports?
The limit of 45 has been prescribed by ICAI not

Income Tax Department
Yes, you can upload more than 45 audit reports,

portal will happily accept more than 45 tax audit
reports in form 3CA/3CB (with 3CD of course)
Peer review by ICAI
If portal can accept more than

45 reports, how will ICAI know?
As per arrangement between ICAI and ITD, ITD will
provide will provide periodic member wise upload
position to ICAI.
How will be 44AD/44AE

reports identified?
The MIS provided by ITD will segregate 44AD/AE and
other reports.
If portal can accept more than

45 reports, how will ICAI know?
As per arrangement between ICAI and ITD, ITD will
provide will provide periodic member wise upload
position to ICAI.
How will be 44AD/44AE

reports identified?
The MIS provided by ITD will segregate 44AD/AE and
other reports.
Do I need to file Directors

report?
NO
I am branch auditor. Do I
need to e-file TAR?
NO. Branch audit report will be consolidated with HO
audit report and HO audit report need to be e-filed.
Can any information like

Quantitative Details be attached as
annexure along with financial
statements?
NO, all quantitative details need to be filled in XML format
itself.
I find filling details of additions/sale

of Fixed Assets very cumbersome.
Can I attach an annexure with
financial statement?
NO, all line items related to additions/sale of fixed assets
needs to be filled in XML format itself.
If an assessee has voluntarily got his

account audited and obtained 3CB,
then is it necessary to upload the
audit report?
No
Do I need to upload statutory audit

report and financial statements, of a
company not subjected to tax audit?
Only ITR needs to be filed in this case.
Within how much period the assessee

has to accept the audit report after
being e-filed by auditor?
No time limit per se. But it may be accepted before
expiry of due date u/s 44AB to avoid penalty
proceedings u/s 271B, since the day on which
assessee accepts TAR filing, shall be considered
as date of furnishing.
Questions please?
Thank you!
CA. Deepak Bholusaria
[email protected]

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e-Filing of audit report

under Income Tax Act,

Assessee deliberately did not disclose some or all

Assessee didnt disallow some expenses, even if they

Since Return of Income (ROI) did not contain tax audit

Many assessees used fake CA membership number, in

Goal and Objective

Understanding key requirements for e-filing

Understanding types of audit reports which

Discussion on flow of process and

Challenges and solutions.

Tips and tricks.

Compatible operating system (XP/SP3, Win7/8

Compatible Web browser (IE/Chrome/FireFox)

Java Min. Ver should be JRE 1.7 update 13

Offline report preparation software to generate

Financial statements and other documents are

Valid digital signatures of auditor and assessee

Access credentials to e-filing portal

Type of various forms

Proviso to rule 12(2)*

Total e-filing forms

other than ITR - as on August 7, 2013

* Form 3CA-3CD / 3CB-3CD counted as one form

Mandatory e-Audit reports

as per proviso to rule 12(2) For AY 2013-14

Specified Audit Report Form No.

Red coloured forms are online forms

What about audit reports for

Reports for audits conducted under section 44AD

Audits conducted under Section 44AD & 44AE of

*There is no reference to section 44BB/44BBB in ICAI guidelines

Report u/s section 115JC

Report in form no. 29C u/s 115JC of

Trusts required to obtain

Reports in form no. 10B/10BB are

Registration Tax professional

Only Chartered Accountants holding full time

No firm can be registered as Tax

Only an Individual CA can register. All

Registration Tax professional

Six digit membership number

Date of Enrolment as member of ICAI

Name (as per PAN data)

PAN Based digital signature

(should be same as per ICAI and ITD)

Registration Tax professional

First 4 alphabets are fixed ARCA

In case you forget your password it can be

Akin to appointment of auditor (This will not replace

Before any auditor can upload digitally signed XML

Assessee logins to portal using his PAN based

This is a one time exercise to be done by assessee

Before an assessee can exercise Add CA option,

Auditors Tax Professional user id must be active.

Assessee may authorise one CA for more than 1

Only one CA can be added for a particular form and

Adding CA Multiple Auditors