COMPARISON OF TDS AND TCS REQUIREMENTS
IN OLD AND NEW FORM NO. 3CD AS REQUIRED
FOR TAX AUDIT U/s 44AB OF THE INCOME TAX ACT
Now Chartered Accountants will have to verify and certify details of TDS and TCS in a very elaborative manner and will have to check TDS/TCS (returns) statements of each quarter in detail.
(1) In Old form No. 3CD:- 27(a) :- (i) complied with all TDS obligations or not as per Chapter XVII-B,
(ii) earlier there was no need to inform about non compliance of TCS provisions.
(1) In New Form No. 3CD:- 34(a):- Now section wise details of TDS and TCS are required to be given.
(2) In Old form No. 3CD:- Show amount of Tax deductible and not deducted at all
(2) In New Form No. 3CD:- Show Section wise Gross amount on which tax was required to be deducted or collected
(3) In Old form No. 3CD:- Give amount and details of shortfall in TDS deducted
(3) In New Form No. 3CD:- (i)Give Sectionwise gross amount on which tax was deducted or collected at lesser rate.
(ii) Give sectionwise amount of TDS and TCS deducted or collected at lesser rate.
(4) In Old form No. 3CD:- Give amount and details of TDS deducted late
(4) In New form No. 3CD:- Give amount and details of Tax deducted but not paid
(5) In New Form No. 3CD:-
(i) Give section wise total amount of payments or receipts, e.g. give gross amount of interest other than interest on securities, gross payment of freight, etc., even if liable to TDS/TCS or not Sec. 192,193, 194, 194A, 194B, 194BB, 194C, 194D, 194E, 194H, 194I, 194IA, 194J, 195, 206C(1), 206C(1C), 206C(1D). However disallowance U/s 192& 194IA will become applicable from A.Y. 2015-16.
Disallowance U/s 40(a)(ia) presently covers Sec. 193, 194A, 194H, 194I, 194J, 194C, 195(40a-i).
(ii) Give Section wise gross amount on which tax was required to be deducted or collected.
(iii) Give sectionwise gross amount on which tax was deducted or collected.
(iv) Give Sectionwise gross amount on which TDS/TCS was deducted or collected at specified rate.
(v) Give sectionwise amount of TDS and TCS at specified rate.
(6) In New Form No. 3CD:- Details of TDS statement filed:-
(i) If TDS/TCS statement filed in prescribed time then no need to give information required in 34(b).
(ii) If TDS/TCS statement not filed within prescribed time then give due date of furnishing, give date of furnishing if furnished in time.
(iii) There seems controversy in para 34(b), that, if TDS/TCS statement is not filed within prescribed time then give information Whether statement of TDS/TCS contains information about all transactions which are required to be reported. And if TDS/TCS statement filed within prescribed time then there is no need to give information that TDS/TCS statement contains all required information. If TDS statement is not filed in time then information will also have to be furnished regarding form No. 15G/15H/27C and payment to transporters, not incorporated in statement. It will be difficult for bank auditors and for voluminous payment to transporters etc.
(7) In New Form No. 3CD:- Amount of Interest payable and paid:-
34.(c) If liable to pay interest U/s 201(1A)/206C(7) on delay payment or deduction/collection of TDS/TCS give amount of such interest payable .
(ii) Also give amount of interest paid.
CA RAJESH MEHTA, INDORE