Sub: Exposure Draft - 'Guidance Note on Tax Audit under section 44AB of the Income-tax Act,1961' for Public Comments

In August, 2023, the Direct Taxes Committee (DTC) had come out with a Revised Edition of "Guidance Note on Tax Audit under section 44AB of the Income-tax Act,1961 (Revised 2023)". Thereafter, in June, 2024, the DTC had come out with 'Implementation Guide on Revision in Form No. 3CD and Form No. 3CEB in March, 2024', containing specific guidance on the amendments in Form No. 3CD and Form No. 3CEB vide Notification No. 27/2024 dated 05.03.2024 & Notification No. 34/2024 dated 19.03.2024. The Implementation Guide was to be read along with the Guidance Note on Tax Audit under section 44AB of the Income-tax Act, 1961 (Revised 2023).

Thereafter, amendments to the Income-tax Act, 1961 were made by the Finance (No. 2) Act 2024 and Finance Act 2025. Also, recently, the CBDT has issued Notification No. 23/2025 dated 28th March 2025, notifying further amendments to Form No. 3CD, which come into effect from 1st April 2025.

Considering these recent changes in Form No. 3CD and amendments by the Finance (No. 2) Act 2024 and Finance Act 2025 in the Income-tax Act, 1961, DTC proposes to revise the "Guidance Note on Tax Audit under section 44AB of the Income-tax Act, 1961 (Revised 2023)" for the benefit of the members. Accordingly, the Exposure Draft - 'Guidance Note on Tax Audit under section 44AB of the Income-tax Act, 1961', incorporating the proposed changes, has been issued for public comments. The Exposure Draft can be accessed at the link https://resource.cdn.icai.org/86832dtc-exp-draft-44ab.pdf

Invitation to Comment

Comments are invited on any aspect of this Exposure Draft. Comments are most helpful if they-

• indicate the specific paragraph or group of paragraphs of the Guidance Note to which they relate and the specific clause of Form No.3CD (in case the suggestion pertains to that clause);
• contain a coherent rationale, and
• provide a clear suggestion for the change

Also, comments may be in the form of supplementing any para in the Exposure Draft with relevant case law of the Supreme Court/relevant Circular/Notification.

How to Comment?

The comments on the above mentioned Exposure Draft are to be sent at the following link latest by 20th July, 2025 - https://docs.google.com/forms/d/e/1FAIpQLSfNvQp-lghZPWHe8134JVjHQQndAHcj5XmZDUbl-fjXTIccIA/viewform