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Latest FAQ On UDIN for Practicing Chartered Accountants – Part 3 (Authorities/Regulators, Bank Audit, UDIN for GST &Tax Audit)

Authorities/Regulators/Banks/Others

1. How do Authorities/Regulators/Banks/Others can search UDIN?The UDIN so indicated on certificate can be searched through the search option on UDIN Portal by sharing few details such as Name of the Authority, Mobile Number and Email of the person searching the UDIN. However they are not required to register themselves on the UDIN Portal.

2. For searching UDIN, whether a regulator/third party requires to register on UDIN portal.

No Registration is required for regulator/third party to search the certificate. For searching the UDIN regulator/third party has to mention UDIN number, Mobile number, email ID and Name of the authorities searching UDIN.

3. Which types of regulators/third parties can ask for UDIN

ICAI has made awareness about mandatory applicability of UDIN to all regulators like RBI, SEBI, CBDT, MCA, IBA and they can very well ask for UDIN.

Bank Audit

1. Whether UDIN is mandatory for Statutory Bank Audit?

For Statutory Bank Audit, UDIN is not mandatory. However, for all Certificates to be signed while conducting Bank Audit, generation of UDIN is mandatory as UDIN is already mandatory on all Certification w.e.f 1st Feb.,2019.

2. While conducting Bank Audit, whether separate UDIN has to be taken for all Certificates as there are bulk of certificates to be signed?

UDIN has to be generated per Assignment per Signatory.

In Bank Branch Audit, One Branch is one assignment, hence, one UDIN for all certificates will suffice.

However, care should be taken that a list of all certificates bearing same UDIN should be compiled and handed over to management under a covering letter so that the UDIN generated cannot be misused by affixing on any other certificate which has not been signed by you.

3. In case if some Certificates are signed by one Partner while others are signed by another Partner, whether different UDIN is required for each such Partner?

UDIN has to be taken per Assignment per Signatory. Bank Branch Audit per Branch is one assignment and hence one UDIN for all certificates is enough.

However, if different partners are signing different certificates then separate UDIN has to be taken per signatory for the certificates signed by them.

4. Whether UDIN is mandatory for Tax Audit?

In the 2nd phase of UDIN applicability, ICAI Council has made generation of UDIN mandatory for all GST Audit and All Tax Audit from 1st April, 2019. Hence in Bank Branch Audit, separate UDIN has to be taken for Tax Audit.

5. Whether same UDIN which was generated for Certificates in Bank Branch Audit can be used for Tax Audit of the same Bank Branch?

Tax Audit is the separate assignment. Hence separate UDINs have to be taken while conducting Bank Branch Audit for each Branch.

Therefore, 2 separate UDINs are to be generated – one for Certificates and other for Tax Audit Report.

However, if certificates are signed by more than one partner then more UDINs on certificates have to be generated.

6. Whether UDIN is applicable to both Statutory Central Auditors (SCAs) and Statutory Branch Auditors (SBAs)?

Yes, UDIN is applicable to both SCAs and SBAs for Certificates and Tax Audit Reports while conducting Bank Audit.

7. Whether UDIN is to be generated for LFAR and / or other Bank Audit Reports?

As per UDIN applicability in 2nd Phase, UDIN is not required to be generated for LFAR and other Bank Audit Reports now.

8. What is the process to generate UDIN for certificates under Bank Audits?

For generating UDIN, the “Document type” is to be selected as “Certificates”. Thereafter, date of signing of the document is to be mentioned. Under “Type of Certificate” select “Certificate issued by Statutory Auditors of Banks”.

There are 3 mandatory fields for entering the financial figures / values from the document and the description of the figure/ value so entered.

The names of the Certificates are to be mentioned under the Caption “Document Description”.

9. How to generate one UDIN for more than one Certificate when there are 3 mandatory filled to be given from the Certificates?

While generating one UDIN for all the Certificates, some common figures /parameters should be given in 3 mandatory fields and if no common figure is there then name of the Bank and Branch, Advances, Deposits etc must be the one common field which can be correlated with all the certificates.

10. Whether UDIN is mandatory for Tax Audit Reports that are filed online using Digital Signature?

UDIN will be applicable both for manually as well as digitally signed Reports / uploaded online. In case of digitally signed / online reports, UDIN has to be generated and retained for providing the same on being asked by any third party/ authority.

FAQs related to UDIN for GST & Tax Audit by UDIN Monitoring Group of ICAI

1. UDIN is mandatory on which types of Reports with effect from 1st April, 2019?

As directed by the 379th ICAI Council Meeting held on 17th and 18th 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 1st 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?

  1. 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.

  1. 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 3rd 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?

  1. For Section 35(5) of CGST Act, 2017 – Form GST 9C, the mandatory key fields are as under:
    1. Turnover (incl. 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. Financial 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.

  1. 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. Financial 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 Practicing 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.

Author: Niranjan Reddy

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