Maintaining accurate books of accounts is very important. Filing of Audit Reports, Income Tax Returns and GST Returns depends extensively on the information available in the books of accounts. With the introduction of GST, the disclosure requirements for indirect taxes paid have been modified.
The Central Board of Direct Taxes (CBDT) has notified that when assessees are subject to an audit under the Income Tax Act, they have to submit a tax audit report to the Income Tax Authorities. This tax audit report can be furnished in either Form 3CA or 3CB. Along with the audit report, the assessees are required to furnish a ‘Statement of Particulars’ in Form 3CD. Form 3CD asks for the basic details of the assessee and the particulars of various compliances under the Income Tax laws. This form also requires the assessees to disclose details related to GST. These details will help in matching the figures with the GST returns and thus ensuring there is accuracy of data.
In this article, we will list out the clauses in Form 3CD that require GST related details to be disclosed.
Note: Reporting under clause 44 of Form 3CD has been kept in abeyance till 31st March 2021.
|Clause No./Si. No||Particulars (as per Form 3CD)||Details|
|4||Whether the assessee is liable to pay indirect tax like excise duty, service tax, sales tax, [goods and services tax,] customs duty, etc.; if yes, please furnish the registration number or [GST number or] any other identification number allotted for the same||Valid GST registration number of the assessee has to be entered here (if applicable).|
|44||Break-up of total expenditure of entities registered or not registered under the GST||In this clause, the assessee is required to furnish the total amount of expenditure incurred during the year and details of:
If registered under GST laws:
● Expenditure relating to exempt goods/services
● Expenditure relating to entities falling under the composition scheme
● Expenditure relating to other registered entities
● Total payments to registered entities If not registered under GST laws:
● Expenditure relating to entities not registered under GST
- From the above table, it can be inferred that disclosures in clause 44 of Form 3CD have to be made by all assessees (whether they are registered under GST or not).
- Form 3CD has to be signed by the person competent to sign Form 3CA/Form 3CB.