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Revising the Tax Audit Report: An option at e-fling portal
While filing the audit report, the drop box menu at the income tax portal gives the option “original or revised”. It means that the option of a revised audit report is also there at income tax portal for uploading the audit report. It may be noted that the utility provided by CBDT for filling or uploading of the TAX Audit report has been added under heading “OTHERS” under uploading TAB.
The audit report once issued can be revised. The manner in which it can be revised is given by the Institute in SA-560 (Revised) “Subsequent Events”. The Tax Audit report is directly related to taxation and there may be situations which may warrant the revisions of the tax audit report. The guidance Note did not mention anywhere the period by which revision can be done. Further, the revised audit report can also be revised at subsequent events if the situation so arises. SA 560 covers events that are discovered by the auditor after the date of the auditor’s report but before the financial statements are issued. It elaborate that f financial statements are affected by “events occurring between the date of the financial statement and the date of the auditor’s report, and facts that become known to the auditor after the date of the auditor’s report”, an auditor, “shall discuss the matter with the management, determine whether financial statements need amendment and if so inquire how the management intends to do the matter in the financial statements.”
Guidance Note of Tax Audit u/s 44AB of Income Tax Act-1961 very aptly discusses that In certain cases, members may be asked by the board of the director to change the report for the following reasons:
(i) revision of accounts of a company after its adoption in annual general meetings.
(ii) change of law e.g., retrospective amendment.
(iii) change in interpretation, e.g. CBDT’s circular, judgments, etc.
(iv)Any other reason like system/software error requiring change in report already uploaded.
There may be situations where the auditor has failed to report few information in the original audit report like TDS schedule, quantitative details, prior period items etc and to rectify own errors, auditor may wish to revise the audit report.
It may happen that after uploading a Tax report, it may come to the knowledge of the auditor that the client is engaged in another business as well which was not disclosed originally at the time of uploading the report. This may require the auditor to revise the tax audit report.
If a member is revising the audit report then the auditor must mention the fact that it’s a revised audit report in the audit report itself.
It’s a general belief that revising the audit report will be a risky affair from an auditor perspective. This may not be so. In all such cases, the auditor must keep a proper documentation justifying the revisions of the audit report.
Now, the question arises as to whether revised audit report would require new UDIN or old UDIN can be used for this purpose?
It may be noted that UDIN is applicable to every certification. New Tax Audit Report or Revised Tax Audit report is a new certification and so it would require new UDIN to be generated. Auditor need to be cautious as the UDIN need to be generated in a time bound manner and various authorities are asking for UDIN for its verification.