The deadline for submitting an income tax audit report for the financial year 2023-24 (assessment year 2024-25) was October 7, 2024. If you need to make any modifications and submit a revised audit report to replace the originally filed tax audit report, you must do so before the conclusion of the relevant assessment year.
“For the current assessment year of 2024-25, the deadline for uploading a revised tax audit report pertaining to financial year 2023-24 shall be March 31, 2025,” says SR Patnaik, Partner (Head – Taxation), Cyril Amarchand Mangaldas.
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Under what circumstances you can file a revised tax audit report?
Chartered accountant Prakash Hegde says that a tax audit report that has been uploaded can only be revised under specific conditions outlined in Rule 6G.
Ankit Jain, Partner, Ved Jain & Associates explains what Rule 6G says. He says that a revised tax audit report is required to be filed if there are payments that impact disallowances under section 40 or 43B (such as late payment of expenses or taxes) after the tax audit report has been submitted. “If such payments are made before the due date of the ITR but after the initial tax audit, the report can be revised to reflect these adjustments. These include payment of TDS, bonuses, leave encashment or interest to banks,” says Jain.
Hegde says that if only specific payments which require a recalculation of disallowance under section 40 or 43 B then you may file a revised tax audit report. Rule 6G(3), which has been inserted with effect from April 1, 2021, specifies the conditions. They are:
Section 40: Under section 40, there are important provisions regarding the deduction and payment of TDS as required under the Income Tax Act. If the taxpayer has not deducted the TDS or has deducted but not paid it, 30% of the expenditure for resident recipients and 100% for non-resident recipients will be disallowed, meaning it cannot be claimed as an expenditure. However, if the TDS amount is paid on or before the due date for submission of ITR, they are deductible in the year of accrual itself (i.e. in the financial year to which they pertain).
Section 43B: For taxpayers who maintain their books of account on the ‘mercantile system’, expenses are deductible on an ‘accrual’ basis. However, certain expenses are only deductible on a ‘payment’ basis according to section 43B, even for these taxpayers.:
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- Any tax, duty, cess or fee Employer’s contribution to provident fund or superannuation fund or gratuity fund,
- Amount payable as bonus or commission to employees for service rendered or in lieu of leave,
- Interest on any loan from a public financial institution or scheduled bank or cooperative bank,
- Amount payable to micro or small enterprises beyond the time limit specified in the MSME Act etc.
Tax experts recommend that if you are required to submit a tax audit report, it is essential to also file your income tax return. “We cannot file ITR without finalizing Books of Accounts and getting it audited by an accountant as per section 44AB reason being books of accounts form the basis of income and expenditure to be submitted in annual income statement or Income Tax Return,” says Gaurav Gupta, Managing Partner of S G Taxman Solutions.
Akhil Chandna, Partner, Grant Thornton Bharat explains that apart from the reasons mentioned above, a tax audit report can be revised for these other reasons:
- Revision of a company’s accounts after their adoption in the annual general meeting,
- Changes in law, such as retrospective amendments,
- Changes in interpretation, such as those resulting from CBDT circulars or judicial judgments,
- Other reasons, such as system or software errors requiring changes to the already uploaded report.
“The revised tax audit report must be submitted before the end of the relevant assessment year. There is no statutory limit on how many times a report can be revised, provided each revision references previous reports and is properly signed and dated,” says Jain from Ved Jain & Associates.
“To revise the report, obtain a revised audit report from your accountant, duly signed and verified. This revised report must be submitted before the end of the relevant assessment year (in this case, before March 31, 2025, for AY 2024-25),” says Rishabh Malhotra, Advocate.
“Once you submit a tax audit report, it is said to be the final report and you can only file a revised tax audit report if it’s due to section 40 or 43B error. The same rule applies to belated tax audit reports also i.e. tax audit reports filed after the deadline. Practically speaking the Income tax portal at times accepts revised tax audit reports regardless of section 40 or 43 errors. But this can be subject to disputes at a later stage,” says a chartered accountant who did not wish to be named.
