1. CA. Deepak Bholusaria
deepak@bholusaria.com
e-Filing of audit report
under Income Tax Act,
1961

2. • Assessee deliberately did not disclose some or all
adverse remarks of Tax Audit Report.
• Assessee didn’t 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.
Background

3. • 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.
Goal and Objective

4. • 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
Checklist

5. Type of various forms
(other than ITR)
available for e-filing

6. 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.
Proviso to rule 12(2)*
 No Audit report u/s 115JC is required to be e-filed

7. Total e-filing forms
other than ITR - as on August 7, 2013
Total* Mandatory Optional
45 11 34
Total* Offline Online
45 5 40
Total* Initiated
by CA
Initiated by
Assessee
Both
45 19 25 1
* Form 3CA-3CD / 3CB-3CD counted as one form

8. 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

9. 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

10. 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.
Report u/s section 115JC

11. Reports in form no. 10B/10BB are
mandatorily required to be furnished
electronically.
Trusts required to obtain
report in 10B/10BB

12. (for forms initiated by CA)
Process Flow

13. Process flow
1. Register as Tax
Professional –
Chartered
Accountant
2. Auditor ask
assessee to add
him/her using “Add
CA” option.
3. Auditor has to
Download offline
utility and prepare
XML file.
4. Auditor login to
portal and upload
digitally signed
XML file and
attachments.
5. Assessee login
to portal accept
filing. In case of
rejection, auditor
to repeat step 4.
Filling Complete

14. Registration of
Auditor

15. • 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.
Registration – Tax professional

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

17. User id will be like this:
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 – Tax professional
999999ARCA

18. Registration screen

19. Process flow
1. Register as Tax
Professional –
Chartered
Accountant
2. Auditor ask
assessee to add
him/her using “Add
CA” option.
3. Auditor has to
Download offline
utility and prepare
XML file.
4. Auditor login to
portal and upload
digitally signed
XML file and
attachments.
5. Assessee login
to portal accept
filing. In case of
rejection, auditor
to repeat step 4.
Filling Complete

20. Adding CA

21. • 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

22. • 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”
• Auditor’s 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

23. 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 – Multiple Auditors

24. 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.
Adding CA – Signing Member

25. 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.
Can CA be changed?

28. Process flow
1. Register as Tax
Professional –
Chartered
Accountant
2. Auditor ask
assessee to add
him/her using “Add
CA” option.
3. Auditor has to
Download offline
utility and prepare
XML file.
4. Auditor login to
portal and upload
digitally signed
XML file and
attachments.
5. Assessee login
to portal accept
filing. In case of
rejection, auditor
to repeat step 4.
Filling Complete

30. Process flow
1. Register as Tax
Professional –
Chartered
Accountant
2. Auditor ask
assessee to add
him/her using “Add
CA” option.
3. Auditor has to
Download offline
utility and prepare
XML file.
4. Auditor login to
portal and upload
digitally signed
XML file and
attachments.
5. Assessee login
to portal accept
filing. In case of
rejection, auditor
to repeat step 4.
Filling Complete

31. Login and Upload

32. • 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)

33. • 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
Technical requirements
(offline mode)

35. Process flow
1. Register as Tax
Professional –
Chartered
Accountant
2. Auditor ask
assessee to add
him/her using “Add
CA” option.
3. Auditor has to
Download offline
utility and prepare
XML file.
4. Auditor login to
portal and upload
digitally signed
XML file and
attachments.
5. Assessee login
to portal accept
filing. In case of
rejection, auditor
to repeat step 4.
Filling Complete

37. Process flow
1. Register as Tax
Professional –
Chartered
Accountant
2. Auditor ask
assessee to add
him/her using “Add
CA” option.
3. Auditor has to
Download offline
utility and prepare
XML file.
4. Auditor login to
portal and upload
digitally signed
XML file and
attachments.
5. Assessee login
to portal accept
filing. In case of
rejection, auditor
to repeat step 4.
Filling Complete

38. General FAQs

39. • 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)
Will portal accept more than
45 Tax Audit reports?
 Peer review by ICAI

40. As per arrangement between ICAI and ITD, ITD will
provide will provide periodic member wise upload
position to ICAI.
If portal can accept more than
45 reports, how will ICAI know?
How will be 44AD/44AE
reports identified?
The MIS provided by ITD will segregate 44AD/AE and
other reports.

41. As per arrangement between ICAI and ITD, ITD will
provide will provide periodic member wise upload
position to ICAI.
If portal can accept more than
45 reports, how will ICAI know?
How will be 44AD/44AE
reports identified?
The MIS provided by ITD will segregate 44AD/AE and
other reports.

42. NO
Do I need to file Director’s
report?
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.

43. NO, all quantitative details need to be filled in XML format
itself.
Can any information like
Quantitative Details be attached as
annexure along with financial
statements?
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.

44. No
If an assessee has voluntarily got his
account audited and obtained 3CB,
then is it necessary to upload the
audit report?
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.

45. 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.

46. Questions please?

47. Thank you!
CA. Deepak Bholusaria
deepak@bholusaria.com