What is the Deadline to File a Revised Income Tax Audit Report?
The deadline for submitting an income tax audit report for the financial year 2023-24 (assessment year 2024-25) was October 7, 2024. If modifications are needed, the revised audit report must be filed before the end of the relevant assessment year. For the current assessment year 2024-25, this means the deadline to submit a revised audit report is March 31, 2025.
SR Patnaik, Partner (Head – Taxation) at Cyril Amarchand Mangaldas, explains, “The deadline for uploading a revised tax audit report for the financial year 2023-24 is March 31, 2025.”
Under What Circumstances Can You File a Revised Tax Audit Report?
A tax audit report can only be revised under specific conditions outlined in Rule 6G. Chartered accountant Prakash Hegde points out that a revision is typically required when there are payments that impact disallowances under section 40 or 43B. For example, if such payments are made after the initial audit but before the due date for filing the income tax return, the audit report can be revised.
Ankit Jain, Partner at Ved Jain & Associates, adds, “These payments include late TDS payments, bonuses, leave encashment, or interest to banks. If these adjustments are made before the due date of the income tax return but after the initial audit, the report can be revised accordingly.”
Key Provisions Under Section 40 and 43B
Section 40: This section deals with the deduction and payment of TDS. If TDS is not deducted or deducted but not paid, 30% of the expenditure for resident recipients and 100% for non-resident recipients will be disallowed. However, if the TDS amount is paid before the due date for submitting the income tax return, the expenditure is deductible in the year of accrual.
Section 43B: This section specifies that certain expenses are deductible only on a ‘payment’ basis, even for taxpayers who maintain their books on an ‘accrual’ basis. These expenses include tax dues, employer contributions to funds, bonuses, and interest on loans from financial institutions.
When Should You File a Revised Audit Report?
Gaurav Gupta, Managing Partner at S G Taxman Solutions, advises that you cannot file an income tax return without finalizing the books of accounts and getting them audited. “Books of accounts form the basis of income and expenditure to be submitted in the income tax return,” he notes.
Akhil Chandna, Partner at Grant Thornton Bharat, adds that a tax audit report can also be revised for reasons such as changes in the company’s accounts after an annual general meeting, retrospective amendments in tax law, changes resulting from CBDT circulars or judicial judgments, and software errors.
Submission Timeline: The revised tax audit report must be submitted before the end of the assessment year, i.e., March 31, 2025, for FY 2023-24. Importantly, there is no limit on how many times the report can be revised, as long as each revision references previous versions and is properly signed and dated.
Practical Considerations for Filing a Revised Report
CA (Dr.) Suresh Surana highlights that the conditions for filing a revised audit report under Sections 40 and 43B must be satisfied. “The deadline for filing the revised report is March 31, 2025, for payments made after the original submission, which necessitate recalculations,” says Surana.
Rishabh Malhotra, Advocate, suggests, “To revise the report, obtain a new version from your accountant, duly signed and verified, and submit it before March 31, 2025.”
Common Issues and Exceptions
Once filed, a tax audit report is considered final unless it requires revision due to Section 40 or 43B errors. However, according to some tax practitioners, the Income Tax Portal occasionally accepts revised reports regardless of such errors, although this could lead to future disputes.
A revised tax audit report provides a way to ensure accuracy in financial reporting, especially in case of any adjustments that affect deductions and compliance. Staying aware of the circumstances and deadlines for revision will help you remain compliant and avoid any potential penalties.