File No.
ICAI/ClTAX/2014-15/Rep/02
THE ]INSTITUTE OF
CHARTERED ACCOUNTANTS OF INDIA
(Set up by an Act of
Parliament)
‘ICAI Bhawan’,
Indraprastha Marg,
New Delhi – 110 002.
INDIA
Dated: 13/11/2014
Sh. Ashish Abrol
Directorate of Income Tax (Systems),
Aayakar Bhawan, Vaishali, Sector-3,
Ghaziabad, 201010,
Uttar Pradesh
Subject: Representation Form No.
3CEB for reporting of International Transactions and Specified Domestic
Transactions to be submitted online on the website of Income-Tax Department
Respected Sir,
As you are aware that Form No.
3CEB for reporting of International Transactions and Specified Domestic
Transactions is required to be submitted online mandatorily. In this regard,
the Central Board of Direct Taxes (‘CBDT’) has notified the utility for
preparation of the Form No. 3CEB.
There could be various
situations, wherein the certifying Chartered Accountants needs to provide basis
of preparation/ qualifications/ Disclaimer/ clarification while singing the
Form 3CEB. As the Form 3CEB is in the nature of certificate, flexibility should
be provided to the auditor to express his opinion.
It is also requested that the
utility notified by the CBDT incorporates the flexibility to allow auditors to
provide notes to make additional disclosures.
As in case of e-filing of the tax audit
report, space is provided for making observation/qualification in support of
the tax audit report in Form 3CA and 3CB. This provides flexibility to the
auditors for disclosures of any position adopted. A similar facility should
also be provided in respect of e-filing of from 3CEB.
We believe that an urgent action
is needed in this regard on the above lines and the necessary modifications be
made in the Utility.
Regards
Yours sincerely
CA. K. Raghu
President, ICAI
