Clause 27 of tax audit

According to the guidance note issued by the Institute of Chartered Accountants of India (ICAI) on tax audit under section 44AB of the Income Tax Act, 1961, clause 27 of Form 3CD is applicable only for the assessment year 2018-19 and onwards. Therefore, if you are filing the tax audit report for the assessment year 2023-24, you are required to fill clause 27 along with clause 44.

Clause 27 requires the reporting of the amount of modified value added tax credits (MVAT) availed of or utilised during the previous year and its treatment in the profit and loss account. MVAT refers to the input tax credit of central excise duty, service tax, value added tax, entry tax, etc. that is available for set-off against the output GST liability. Clause 27 also requires the reporting of the amount of GST paid/payable in cash and through input tax credit as per the GST returns filed during the previous year.

Clause 44 requires the reporting of the break-up of the total expenditure of entities registered or not registered under the GST. It also requires the reporting of the expenditure relating to goods or services exempt from GST, expenditure relating to entities falling under the composition scheme, and expenditure relating to other registered entities. The purpose of this clause is to ensure the reconciliation of the expenditure reported in the books of accounts and the GST returns.

According to the guidance note issued by the Institute of Chartered Accountants of India (ICAI) on tax audit under section 44AB of the Income Tax Act, 1961, It is pertinent to note that since implementation of GST from July 1, 2017, central excise duty has been subsumed in GST and is leviable only on six products viz. petroleum crude, diesel, petrol, aviation turbine fuel, natural
gas and tobacco. Hence, reporting under this clause is restricted for only those assessees who deal in these products. 

~CA Deepak Jaisinghani

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