New Audit Report Requirements for Charitable Institutions
CBDT has issued a new audit report form, 10B and 10BB, for charitable institutions, demanding extensive requirements from the assesses. The notification applies from April 1, 2023, emphasizing the need for improved accounting practices. The applicability of Form 10B and 10BB differs based on the institution's registration status and income criteria. The shift to computerized accounting is crucial, considering the evolving regulatory landscape.
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Discussion Analysis Report Charitable Institutions & New Critical Audit on 10B/10BB Presented By- CA Naresh Kumar Kabra 1
Notification Related to New Audit Report Form As per Notification No. 7/2023, dated 21.02.2023, CBDT issued New Audit Report Form 10B & 10BB for charitable institutions. The report of audit of the accounts of a fund or institution or trust or any university or other educational institution or any hospital or other medical institution which is required to be furnished under clause (b) of the tenth proviso to clause (23C) of section 10 & sub- clause (ii) of clause (b) of sub-section (1) of section 12A shall be in- Form 10BB Form 10B R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 2 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Irony Related to the Notification Almost after the completion of 11 months of Financial Year 2022-23, a notification has been issued by CBDT about the Audit Report of charitable institutions, which demands huge list of requirements by the assessee. Applicability of this Audit Report comes from April 1, 2023, which means that Audit Report for F.Y. 2022-23 has to be filed in the newly prescribed format. The most important thing is that, this notification comes for those assessees which requires more improvement w.r.t accounting among all the assessees covered under the Income Tax Act. Most of the assessees in this sector has not shifted completely to the computerized system of accounting. maintaining the books of accounts in completely hand written formats also known as Bahi Khata. Moreover, some of them are still R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 3 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
- Applicability of Form 10B & 10BB (OLD) Form10B Form 10BB If the charitable institution was registered under section 12AB of Chapter III of Income Tax Act,1961. If the charitable institution was registered under section 10(23C) of Chapter III of Income Tax Act,1961. Earlier, there was no concept of the small trust or big trust i.e., based upon criteria of gross receipts of Rs. 5 Crore, Audit report format (whether Form 10B or 10BB) was decided according to the section under which Trust was registered. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 4 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Applicability of Form 10B & 10BB (NEW) Form 10B Form 10BB The total income of the charitable institution, exceeds rupees five crores during the previous year; or Such charitable institution has received any foreign contribution during the previous year; or If the conditions of Form 10B are not applicable, then Form 10BB has to be filed. Such charitable institution has applied any part of its income outside India during the previous Year. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 5 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Explanation related to applicability of Audit of Trusts TOTAL INCOME while assessing the applicability limit means the Gross Receipts of the charitable institution which includes all the income of such institution i.e., revenue from direct & indirect sources. For Example:- ABC Trust has following details w.r.t A.Y. 2023-24:- Expenditure Amount (Lakhs) 1.50 Income Amount (Lakhs) 2.50 To Distribution of Blanket By Donation received To Excess of income over Expenditure TOTAL 2.00 By Interest income 1.00 3.50 TOTAL 3.50 In addition corpus received for Rs. 5.00 Lakhs Here, Question arises, How Gross receipt (total income) will be calculated? What will be treatment of Corpus? R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 6 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Explanation related to applicability of Audit of Trusts Here, Total Income of ABC Trust for applicability of 10B will be calculated as sum of :- Particulars Amount (Lakhs) Interest Income Donation Income 1.00 2.50 Corpus 5.00 Total 8.50 Thus, the Total Income for calculating the limit for Form 10B is 8.5 Lakhs. Note :- While calculating the Total Income, Corpus donations will be considered & it will be added in gross receipts. There s no relation of Total Income with the Net income over expenses. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 7 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Coverage in Form 10B/10BB All amendments of Income Tax Act Also covers provision in addition to Chapter III Earlier 10B Earlier 10BB ITR- 7 Compilation of Personal Information details of Trust and Trustee Assessment Order of AO Assessment Order of CIT Assessment Order of ITAT Order of HC Order of SC Experience of registration under new law Registration Form 10A/ 10AB Notification for Books of accounts New Audit Report Format is the consolidation of: It will make filing of ITR 7 easier. In nutshell, it is a compilation of trust laws from start to end & are self speaking self Assessment Order for CI duly certified by CA, only for the ease of Department. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 8 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Comparison Old vs New (Form 10B & 10BB) Major Additions in 10B & 10BB New Audit Report Old Audit Report 40(a)(ia) 40(A)(3) 10B: 17-18 Pages (Big trust- More than Rs. 5 Crores) 10BB: 10-12 Pages (Small trust- Less than & equal to Rs. 5 crores) 269SS/ST/T 10B: 5 Pages 10BB: 6 Pages Details of capital assets transferred TDS on receipts Books of account as per Rule 17AA Donations received in Kind 10B: 8+8 Clauses 10BB:19 Clauses 10B: 49 Clauses 10BB: 32 Clauses Payment in excess of 50 Lakh in AOI Management details Advancement of GPU Bifurcation of application of income in electronic & non electronic mode TDS provisions of Chapter XVII-B or XVII-BB & many more R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 9 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Is it Worth it To do comparison between Old vs New Audit Report Form?? R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 10 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Overview of Form 10B 1 General Information Total Clauses (related to General information) 20 Basic Details (Clause 1 to 6) Legal Clause (Clause 7 to 8) Registration Details (Clause 9) Management Details (Clause 10) Object (Clause 11 to 12) Commencement of Activities (Clause 13) Details of Place where books of accounts as per Rule 17AA and other documents have been maintained (Clause 14) Advancement of GPU (Clause 15 to 16) Business Undertakings (Clause 17) Business Incidental to objects (Clause 18) Details of Receipts where TDS is deducted (Clause 19) Applicability of Provisions of Section 13(10) (Clause 20) R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 11 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Overview of Form 10B 2 Computation of Taxable Income Total Clauses 14 Voluntary Contributions (Clause 21 to 27) Income to be applied (Clause 28 to 30) Application of Income (Clause 31) Most Important and trickiest Part of the form Taxable income (Clause 32) Income Taxable under Section 115BBI (Clause 33) Anonymous Donation chargeable to tax (Clause 34) R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 12 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Overview of Form 10B Other Reportable Clauses 3 Total Clauses 15 Other Income (Clause 35) Capital Assets u/s 11(1A) (Clause 36) Application of Income out of different sources other than Income (Clause 37) Payment or credit in excess of Rs. 50 Lakhs to a Single person during previous year (Clause 38) Details of Income u/s 13(10) (Clause 39) Details of expenses for religious purpose for 80G registered Trusts (Clause 40) Details of 13(3) Persons Specified Persons (Clause 41-42) Details of Specified violation u/s 13(2) Specific Violations (Clause 43) Details of claim of Depreciation where cost of asset is already claimed (Clause 44) Details of deduction u/s 10 (Clause 45) Details regarding Section 269SS (Clause 46) Details regarding Section 269ST(Clause 47) Details regarding Section 269T (Clause 48) TDS requirement as per Chapter XVII-B or Chapter XVII-BB (Clause 49) R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 13 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Overview of Form 10BB 1 General Information Total Clauses 11 Basic Details (Clause 1 to 6) Legal Clause (Clause 7 to 8) Management Details (Clause 9) Commencement of Activities (Clause 10) Details of Place where books of accounts as per Rule 17AA and other documents have been maintained (Clause 11) R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 14 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Overview of Form 10BB 2 Computation of Taxable Income Total Clauses 15 Voluntary Contributions (Clause 12 to 20) Income to be applied (Clause 21 to 22) Application of Income (Clause 23) Taxable income (Clause 24) Income Taxable under Section 115BBI (Clause 25) Anonymous Donation chargeable to tax (Clause 26) Other Reportable Clauses 3 Total Clauses 6 Application of income out of different sources (Clause 27) Details of 13(3) Persons Specified Persons (Clause 28-29) Details of Specified violation u/s 13(2) Specific Violations (Clause 30) Details of claim of Depreciation where cost of asset is already claimed (Clause 31) TDS requirement as per Chapter XVII-B or Chapter XVII-BB (Clause 32) R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 15 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Clause to Clause Discussion R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 16 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
COMMON CLAUSES 15 Common Clauses in Form 10B & 10BB R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 17 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Clause to Clause Discussion of 10B & 10BB GENERAL DETAILS Common Clauses Clause 1 to 8 are same in both the forms 10B & 10BB w.r.t general information of assessee. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 18 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Here the problem emerges that if assessee has not submitted any intimation to the jurisdictional assessing officer, then whether we should report the other addresses if any of the books of account are kept at that place? Auditor shall give qualification in the observation/qualification paragraph of Audit Report. Since department has already notified through notification dated 10thAug 2022, to intimate the addresses of other places where books of accounts are kept, now it is certifying from auditor whether such addresses were intimated to assessing officer. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 19 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Clause to Clause Discussion of 10B & 10BB Management Common Clauses Clause 10/9 of Form No. 10B/10BB respectively. Reporting under this clause will now lead to processing of information by department, furnished while filing Form 10A/10AB for obtaining registration which may challenge the filed form in case of any deviations between both of them. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 20 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Clause to Clause Discussion of 10B & 10BB Common Clauses In case any person holds status of more than one relation as mentioned in above list, then which relation has to be mentioned w.r.t such person? Mention two line items specifying both the relation of that person with the charitable institution. It may happen where there are large number of members/trustees/officer bearers, which may create significant challenge to enter such large details in this clause. We need to go through offline utility (via some software) where it gives option to directly import file of such members. R SOGANI & ASSOCIATES JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023 SEMINAR ON CURRENT ISSUES 21
Clause to Clause Discussion of 10B & 10BB Common Clauses Here, in this clause we have to report details of authors & founders who does not hold any designation in charitable institution even during the previous year. The same information is also required to be furnished in clause 41 of Form 10B & clause 28 of Form 10BB too. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 22 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Clause to Clause Discussion of 10B & 10BB Common Clauses Anonymous Donation Clause 34/18 of Form No. 10B/10BB respectively. Anonymous donation means any voluntary contribution referred to in section 2(24)(iia), where a person receiving such contribution does not maintain a record of the identity indicating the name and address of the person making such contribution and such other particulars as may be prescribed. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 23 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Clause to Clause Discussion of 10B & 10BB Specified Persons Common Clauses Clause 41 & 42/28 & 29 of Form 10B/10BB respectively. For Clause 28/41, in case of trusts have large number of trustees, it is highly problematic to fill details of each members of trustees, which can be filled by using the offline utility (via software). R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 24 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Clause to Clause Discussion of 10B & 10BB Common Clauses When we select the code 2 i.e., any person who has made a substantial contribution to the trusts or institutions, then only the amount tab is activated & respective amount has to be filled. The assessee is required to maintain the records of specified person as referred in section 13(3), in case such records are not maintained then how to report such details? In such cases, auditor shall give observation/qualification in audit report. Here, now the problem is that if any trust has huge number of line items of specified persons, then while filling Form 10BB it will be very difficult to fill one by one line item so again here the need of offline utility arise (i.e., via software). From the circular dated 09thOct 2023, it has become optional to fill the details of specified person if such details are not available. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 25 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Clause to Clause Discussion of 10B & 10BB Specified Violations Common Clauses Clause 43/30 of Form No. 10B/10BB respectively. In all the above clauses, if any of the violations has been selected as Yes , it may lead to consequences of scrutiny by Department. It will be auditor s professional skepticism to report appropriate responses with proper supporting if No is selected. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 26 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Clause to Clause Discussion of 10B & 10BB Claim of Depreciation Common Clauses Clause 44/31 of Form No. 10B/10BB respectively. It has to be ensured that assessee is not claiming depreciation on those capital assets whose application of income has already been considered while computing the application for the year in which such capital assets has been acquired. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 27 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
TDS/TCS required to be deducted/ collected Clause to Clause Discussion of 10B & 10BB Common Clauses Clause 49/32 of Form No. 10B/10BB respectively. This Clause is similar to the details required to be furnished in tax audit reports (3CA/3CB-3CD) where following details are required to be reported:- 1. TDS required to be deducted under various sections & tax deducted 2. Details of forms furnished w.r.t tax deducted (24Q/26Q/27Q) 3. Amount of Interest payable u/s 201(1A) & interest paid R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 28 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
There shall be no difference in the information required to be filled in ITR-7 in comparison to reporting in Audit report. This Audit Report will definitely make the practicioner expertise in Trust Law!! R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 29 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Detailed Clauses in Form 10B Part of clause indicated in RED BOX are common in both FORMS R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 30 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Clause to Clause Discussion of 10B & 10BB Commencement of activities Which are more detailed in 10B Clause 13/10 of Form 10B/10BB respectively. Special Focus Date of Commencement of Activities R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 31 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Clause to Clause Discussion of 10B & 10BB Common Clauses All the forms i.e., Form 10A, Form 10AB were filed using the DSC of client itself. But now department is keen to certify such details of commencement of activities & date of application for provisional registration by the auditor. If in any case, incorrect information is being furnished or there exists mismatch between the audit form & earlier filed forms, then it may lead to enquires from department demanding the withdrawal of registration granted to such institution. Department is also collecting the auditor s certified data from its assessees in order to process such information and issues notices to those charitable trusts who have submitted wrong/incorrect information. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 32 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Place of books of account Clause to Clause Discussion of 10B & 10BB Which are more detailed in 10B Clause 14/11 of Form 10B/10BB respectively. Here the problem emerges that if assessee has not submitted any intimation to the jurisdictional assessing officer, then whether we should report the other addresses if any of the books of account are kept at that place? Auditor shall give qualification in the observation/qualification paragraph of Audit Report. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 33 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Clause to Clause Discussion of 10B & 10BB Which are more detailed in 10B Here, form is giving option at last i.e., any other documents containing any other relevant information as per rule 17AA(1)(d)(x) which gives endless options for specifying the documents. Department has prescribed a huge list of books of account or other documents which are not even prescribed in case of other assessees. R SOGANI & ASSOCIATES JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023 SEMINAR ON CURRENT ISSUES 34
Clause to Clause Discussion of 10B & 10BB Which are more detailed in 10B R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 35 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Clause to Clause Discussion of 10B & 10BB Which are more detailed in 10B Since department has already notified through notification dated 10th Aug 2022, to intimate the addresses of other places where books of accounts are kept, now it is certifying from auditor whether such addresses were intimated to assessing officer. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 36 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Voluntary Contribution Clause to Clause Discussion of 10B & 10BB Which are more detailed in 10B Clause 21,22,23/12,13,14 of Form 10B/10BB respectively. 10BB require only gross amount of donations not reported/ not required to be reported in Form 10BD. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 37 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Clause to Clause Discussion of 10B & 10BB Which are more detailed in 10B Clause 23(v) is mainly discussed about the donations which are received in kind but the question arise about the calculation of amount of donations which are received in kind there is no specific guidance on how to ascertain the amount of donation received in kind. Auditor should take management response for the donation received in kind. Notification dated 10thAug 2022 has already conveyed to keep the details of donation received in kind, so assessee can t step back for providing the details of such donation. Taking reference of AS-12 Government Grants , donation received in kind can be ascertained based upon nominal value of such goods received in kind which has also to be reported in financial statements for true & fair view. Technical guide on Donation received in kind:- R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 38 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Clause to Clause Discussion of 10B & 10BB Which are more detailed in 10B Clause 26/17 of Form 10B/10BB respectively. Form 10B requires details of corpus donation received, invested, its application & its purpose. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 39 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Clause to Clause Discussion of 10B & 10BB Which are more detailed in 10B Clause 29/19 of Form 10B/10BB respectively. Here, irony is that Form10BB also requires reporting of income applied outside India although if any amount is applied outside India, then 10BB can t be filed as per the conditions of applicability of Form 10BB/10B. This clause also requires detailed reporting of income applied outside India for promoting international welfare in which India is interested. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 40 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Clause to Clause Discussion of 10B & 10BB Which are more detailed in 10B Now comes the most difficult one. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 41 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Application of Income Clause to Clause Discussion of 10B & 10BB Which are more detailed in 10B Clause 31/23 of Form 10B/10BB respectively. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 42 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Clause 31 (i) Form 10B Application of Income 1 Application of income excluding application not eligible and reported under serial number 37 of Form 10B. Bifurcation of Application of Income (Object Wise) 2 Application of income should be bifurcated as per the objects reported under serial number 11 of Form 10B. Now, here is a catch that if the client bifurcated application of income in objects specified under clause 11, those objects should be reconciled with objects specified in Form 10AB. Otherwise it may attract scrutiny. Another catch is point (IX) of Clause 31 sub-clause(b), which talks about application which cannot be specifically categorized under objects at I TO VIII of Clause 31 sub Clause (b), now if we select in this head then again, scrutiny may be attracted as all the objects according to section 2(15) is already specified in above points. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 43 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Bifurcation of Application of Income (Electronic & Non-Electronic) 3 Application of income should be bifurcated in two modes one is electronic and other one is non- electronic. Electronic modes includes which are referred in rule 6AABA of income tax rules,1962: Credit card Debit card Net Banking IMPS UPI RTGS NEFT BHIM All other modes of payment other than specified above will be classified as non electronic modes of Payment. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 44 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Treatment of various Adjustments ?? 4 Advances /Prepaid Expenses Since, department has not given any clause in which advances can be reported, so such advances can be shown under Amount actually paid during the previous year which accrued during any earlier previous year but not claimed as application of income in earlier previous year. Outstanding Creditors Outstanding Creditors as on 01.04.2022 should be shown in sub clause (iv) of Clause 31. Outstanding Creditors should be shown in sub clause (iii) of Clause 31. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 45 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
5 Accrual vs Cash basis of Accounting The problem of bifurcation into electronic & non-electronic arises due to the maintenance of books of accounts on accrual basis. If assessees have maintained books on cash basis, then it may have assisted in easy bifurcation of application of income into electronic & non-electronic. We have to show the amount of outstanding liability in clause 31(i), then only we will be able to deduct such amount from Clause 31(iii), as Form is designed in such a manner in which have to report in this way. 6 Another, question arises, where to show such amount, whether in electronic or non-electronic? R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 46 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Clause 31 (ii) Form 10B Details of application out of (i) (a) and (i) (b) of Clause 31 1 Here, the requirement of this clause is that if during the previous year, if payment or credit is made to any person in excess of Rs. 50 lakhs then following details of that person are required to be reported:- Whether any TDS has been deducted Amount of application Name of the person Section under which TDS has deducted Mode of application been PAN of such person Here one dilemma point in this form is that, department wants to ask you about the details of those person whom the auditee has paid or credited more than Rs. 50 lakhs to a person during the previous year in 2 clauses 31(ii) and 38, but we need to report under these only when we are filling the figures in Clause 31(i) & 37 respectively. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 47 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Clause to Clause Discussion of 10B & 10BB Which are more detailed in 10B Form 10BB does not require bifurcation as per clause 31 (vi) where bifurcation of application of income into revenue & capital is required to filed. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 48 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Clause to Clause Discussion of 10B & 10BB Which are more detailed in 10B Donation to other trusts not having similar objects Section 40A(3) Disallowance Section 40(a)(ia) Disallowance Any other disallowance R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 49 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
Section 115BBI Clause to Clause Discussion of 10B & 10BB Which are more detailed in 10B Clause 33/25 of Form 10B/10BB respectively. Form 10BB requires only amount of income taxable under section 115BBI. R SOGANI & ASSOCIATES SEMINAR ON CURRENT ISSUES 50 JAIPUR BRANCH OF CIRC OF ICAI- 13/10/2023
