𝐓𝐀𝐗 𝐀𝐔𝐃𝐈𝐓 𝐑𝐄𝐏𝐎𝐑𝐓

Certain queries were received asking whether a 𝐓𝐀𝐗 𝐀𝐔𝐃𝐈𝐓 𝐑𝐄𝐏𝐎𝐑𝐓 can be revised. Here’s my opinion on this matter, and I would appreciate your thoughts, suggestions, or feedback:

1.  𝐆𝐞𝐧𝐞𝐫𝐚𝐥𝐥𝐲, the tax auditor should not revise the tax audit report after signing it.

2.  Before considering a revision, the tax auditor should review 𝐒𝐀 𝟓𝟔𝟎 (𝐒𝐮𝐛𝐬𝐞𝐪𝐮𝐞𝐧𝐭 𝐄𝐯𝐞𝐧𝐭𝐬) to ensure compliance.

3.  The 𝐆𝐮𝐢𝐝𝐚𝐧𝐜𝐞 𝐍𝐨𝐭𝐞 𝐨𝐧 𝐓𝐚𝐱 𝐀𝐮𝐝𝐢𝐭 should also be consulted for guidance.

4.  As per 𝐩𝐚𝐫𝐚 𝟏𝟓.𝟏𝟏, 𝐩𝐚𝐠𝐞 𝟕𝟎 of the Guidance Note, revision may be allowed under certain circumstances, including:
      o 𝐑𝐞𝐯𝐢𝐬𝐢𝐨𝐧 𝐨𝐟 𝐚𝐜𝐜𝐨𝐮𝐧𝐭𝐬 by the company after adoption in the AGM.
      o 𝐂𝐡𝐚𝐧𝐠𝐞 𝐢𝐧 𝐥𝐚𝐰, such as retrospective amendments.
      o 𝐂𝐡𝐚𝐧𝐠𝐞 𝐢𝐧 𝐢𝐧𝐭𝐞𝐫𝐩𝐫𝐞𝐭𝐚𝐭𝐢𝐨𝐧 due to CBDT circulars, court rulings, etc.

5.  The 𝐈𝐧𝐜𝐨𝐦𝐞 𝐓𝐚𝐱 𝐀𝐜𝐭 also permits revision in certain cases. Refer to 𝐬𝐮𝐛-𝐫𝐮𝐥𝐞 (𝟑) 𝐨𝐟 𝐑𝐮𝐥𝐞 𝟔𝐆 of the Income Tax Rules, which allows revision if the assessee has made payments under 𝐒𝐞𝐜𝐭𝐢𝐨𝐧 𝟒𝟎 𝐨𝐫 𝟒𝟑𝐁 after the issuance of the original audit report, necessitating recalculation of disallowances.

6.  In such cases, the 𝐫𝐞𝐯𝐢𝐬𝐞𝐝 𝐫𝐞𝐩𝐨𝐫𝐭 should be filed before the end of the relevant assessment year.

7.  In all cases, the auditor should gather 𝐧𝐞𝐜𝐞𝐬𝐬𝐚𝐫𝐲 𝐝𝐨𝐜𝐮𝐦𝐞𝐧𝐭𝐬 and clearly mention that it is a revised report, with reasons for revision and a 𝐫𝐞𝐟𝐞𝐫𝐞𝐧𝐜𝐞 𝐭𝐨 𝐭𝐡𝐞 𝐨𝐫𝐢𝐠𝐢𝐧𝐚𝐥 𝐫𝐞𝐩𝐨𝐫𝐭.

8.  Other reasons, such as 𝐞𝐫𝐫𝐨𝐫𝐬 𝐢𝐧 𝐬𝐨𝐟𝐭𝐰𝐚𝐫𝐞 or 𝐬𝐲𝐬𝐭𝐞𝐦 𝐦𝐚𝐥𝐟𝐮𝐧𝐜𝐭𝐢𝐨𝐧𝐬, may also necessitate revisions, but these should be carefully evaluated based on the facts of each case.