UDIN for GST & Tax Audit
Institute of Chartered Accountants of India’s 379th Council Meeting held on 17th and 18th December, 2018 made UDIN mandatory for all Tax Audit Reports issued under IT Act, 1961 and GST Audit Reports issued under CGST Act, 2017 with effect from 1st April, 2019.
1. UDIN is mandatory on which types of Reports with effect from 1st April, 2019?
As directed by the 379 ICAI Council Meeting held on 17 and 18 December, 2018 UDIN is mandatory for all Tax Audit Reports issued under IT Act, 1961 and GST Audit Reports issued under CGST Act, 2017 with effect from 1 April, 2019
2. Whether UDIN is also mandatory for Tax & GST Audit Reports that are filed online using Digital Signature?
UDIN will be applicable both for manually as well as digitally signed Reports (like MCA Forms, 15CB) which are uploaded online. In case of no field for mentioning UDIN on digitally signed online reports, UDIN has to be generated and retained for providing the same on being asked by the stakeholders.
3. What is the process to generate UDIN for Tax Audits?
For generating UDIN, the “Document type” is to be selected as “GST & Tax Audit”. Thereafter, date of signing of Report is to be mentioned. Relevant Section of Income Tax Act, 1961 is to be chosen under the Heading “Particulars of Section / Form under which Report issued” from the drop-down box which contains an illustrative list. For reports issued under any other section of IT Act, 1961 which is not appearing in the list, UDIN can be generated by choosing “Other Report under IT Act, 1961” and mention the details under “Document Description” Thereafter, the key fields “Figure/Value/Description” are to be filled for generating UDIN
4. What is the process to generate UDIN for GST Audits?
For generating UDIN, the “Document type” is to be selected as “GST & Tax Audit”. Thereafter, date of signing of Report is to be mentioned. Relevant Section of Central Goods & Services Act, 2017 is to be chosen under the Heading “Particulars of Section / Form under which Report issued” from the drop-down box which contains an illustrative list. For reports issued under any other section of Central Goods & Services Act, 2017 which is not appearing in the list, UDIN can be generated by choosing “Other Report under CGST Act, 2017” and mention the details under “Document Description” Thereafter, the key fields “Figure/Value/Description” are to be filled for generating UDIN.
5. What are the Key fields under “Figures / Values/Description” in Tax Audits as per IT Act, 1961?
A. Under Section 44AB, the following 5 key fields are mandatory:
1. Total Turnover as per Form 3CD
2. Net Profit/ Turnover as per Form 3CD 3. WDV of Fixed Assets as per Form 3CD
4. Assessment Year
5. Firm Registration Number (FRN)
In case where there is no figure/value available in the report related to above mandatory key fields from Sl. No. 1 to 3, mention “0”. The Assessment Year at Sl. No. 4 is to be filled in YYYY-YYYY format. In case, there is no FRN at Sl. No. 5 mention “Not Applicable/NA” and proceed.
Apart from above, one additional key field of PAN is there which is optional. After this there is one more mandatory field as Document Description wherein text between 15 to 50 Characters from some portion of the report has to be mandatorily filled.
B. For Other Tax Audit Reports other than Section 44AB, following 3 key fields are mandatory;
1. Assessment Year
2. Firm Registration Number (FRN)
3. Any Figure/Value from the Report
The Assessment Year is to be filled in YYYY-YYYY format. In case, there is no FRN at Sl. No. 2 mention “Not Applicable/NA” and proceed. For 3 Mandatory field some Figure/Value from report has to be mentioned. In case, there is no figure/value available in the report related to key fields at Sl. No. 3, mention “0” and proceed.
Apart from these, there are 3 additional key fields including PAN of the Assessee which are optional.
After this there is one more mandatory field as Document Description wherein text between 15 to 50 Characters from some portion of the report has to mandatorily filled.
6. What are the Key fields under “Figures / Values / Description” in GST Audits?
A. For Section 35(5) of CGST Act, 2017 – Form GST 9C, the mandatory key fields are as under:
1. Turnover (incld. exports) as per Audited Financial Statements under Clause 5 (A) of Form 9C
2. Turnover as declared in Annual Return (GSTR 9) under Clause 5 (Q) of Form 9C
3. Assessment Year 4. Firm Registration Number (FRN) In case where there is no figure available in the form related to above mandatory key fields from Sl. No. 1 to 2, mention “0”. The Assessment Year at Sl. No. 3 is to be filled in YYYY-YYYY format. In case, there is no FRN as at Sl. No. 4, mention “Not Applicable/NA” and proceed.
Apart from the above, there are 2 more key fields including GSTIN of the Assessee which are optional. There is one more mandatory field as Document Description wherein text between 15 to 50 Characters from some portion of the report has to mandatorily filled.
B. For Section 66(1) of CGST Act, 2017 -Form ADT-04, the mandatory key fields are as under:
1. Short payment of Tax as per Form ADT-04
2. Any other amount as per Form ADT-04
3. Assessment Year
4. Firm Registration Number (FRN)
In case where there is no figure available in the form related to above mandatory key fields from Sl. No. 1 to 2, mention “0”. The Assessment Year at Sl. No. 3 is to be filled in YYYY-YYYY format. In case, there is no FRN as at Sl. No. 4 mention “Not Applicable/NA” and proceed
Apart from the above, there are 2 more key fields including GSTIN of the Assessee which are optional.
There is one more mandatory field as Document Description wherein text between 15 to 50 Characters from some portion of the report has to mandatorily filled.
7. For Tax Audit under Section 44AB, whether separate UDIN is required for Audit Reports like Form 3CA/3CB and Form 3CD?
No, UDIN has to be generated per assignment per signatory, hence, one UDIN to be generated and same UDIN to be mentioned in all the Forms such as 3CA/ 3CB and 3CD.
8. For other GST and/ or Tax Audit Reports, whether separate UDIN is required for various annexures?
No, UDIN has to be generated per assignment per signatory, hence, one UDIN to be generated and to be mentioned in all Annexures if they are part of the Reports.
9. What will happen if I forgot to generate UDIN which are made mandatory by ICAI?
UDIN can be generated till 15 days of signing the document. Further, it may be noted that UDIN generation is being made mandatory as per the Council Decision hence not generating UDIN will amount to non-adherence of the Council Decision and may attract disciplinary proceedings as per clause (1) of Part II of Second Schedule of The Chartered Accountants Act, 1949.
10. Who can generate UDIN?
Only Full time Practising Chartered Accountants with Active status can sign /attest documents and hence are allowed to register on UDIN Portal and generate UDIN. In case of a firm, only signing partner can generate UDIN and no one else on behalf of another can generate UDIN.
11. In case I am a partner in multiple firms, which FRN I should mention while generating UDIN?
The FRN of the Firm on behalf of which the member is signing the Report has to be mentioned. In case there is no FRN as Member is signing in his / her individual capacity, “Not Applicable/NA” to be mentioned against FRN.
For the benefits of Members, UDIN Monitoring Group of ICAI has released detail FAQs on GST & Tax Audit which are available at https://udin.icai.org/faqs
UDIN Monitoring Group of ICAI