| S. No. | Points | Clarifications | Reasons |
| 1 | Head wise Expenditure or Total Expenditure | ||
| 2 | Depreciation, Bad Debts Etc. | ||
| 3 | Salary/Remuneration to Employees | ||
| 4 |
Expenditure relating to Goods or Service exempt from GST (Column 3) |
Following Rate & Exemption Notifications needs to be considered for ascertaining Exempt Supplies:- NNo.1/2017,2/2017, NNo.1/2017,2/2017, Following to be Reported:Alcoholic Liquor Petroleum crude, high speed diesel oil, motor spirit, natural gas and aviation turbine fuel |
As per Section 2(47) of CGST Act,2017-exempt supply cover goods & services with nil rate of tax or which may be wholly exempt from tax under the Integrated Goods and Services Tax Act, and includes non-taxable supply;" "non-taxable supply" means a supply of goods or services or both which is not leviable to tax under this Act or under the Integrated Goods and Services Tax Act" |
| 5 | Expenditure relating to Entities falling under Composition Scheme (Column 4) | General practice of small & medium Taxpayer not to mention GSTIN of Entities falling under Composition Supplier in Accounting Software, hence a suitable remark by Tax Composition Scheme auditor may be given in this regard | |
| 6 | Expenditure relating to other registered entities (Column 5) | Value of Inward supplies other than Supplies from Composition Dealers and Exempt supply from Registered Dealers, are to be mentioned here | |
| 7 | Total Payment to registered entities Column (6) | The word 'payment' should harmoniously be interpreted as 'expenditure' as the Registered Entities combined heading of columns (3), (4), (5) is 'Expenditure in respect of entities (Column 6) | |
| 8 | Expenditure relating to entities not registered under GST (Column 7) | Inward supplies received from unregistered person should be reported here. entities not registered Total of Column (6) and (7) shall tally with Column (2) except to the extent of under GST(Column 7) expenditure mentioned in SN 2 and 3 | |
| 9 | Capital Expenditure | Since, the word used is 'expenditure', it is necessary that the capital expenditure should also be reported. Separate reporting of Capital Exp. Recommended for ease of reconciliation |
Following Disclosures may be given by Tax Auditor
- Regarding the view taken by Assessee to the meaning of 'Total Expenditure & method for filling appropriate Columns.
- If the assessee is not in a position to give the details as required in clause 44, an appropriate disclosure/disclaimer may be made by the auditor in Form 3CA/3CB. Where the assessee has provided reason for not being able to provide details, the same may be reported, if found appropriate.
The article has been contributed by CA Abhas Halakhandi
CAclubindia
