Disclosure of cash transactions in tax audit report

By | August 16, 2018
(Last Updated On: August 16, 2018)

Disclosure of cash transactions in tax audit report

Form 3CD has been Amended vide Notification No. 33/2018, dated 20-7-2018

Requirement of reporting cash transaction is dealt with by clauses 31(ba), 31(bb), 31(bc) and 31(bd).

A snapshot of the disclosure requirements under section 269ST is given below:

ClauseNature of TransactionReporting requirement
31(ba)Receipt of Rs. 2 lakh or above otherwise than by a cheque or bank draft or use of electronic clearing system through a bank account.Name, address and PAN of the payer/payee, nature of transaction, amount of receipt and date of receipt/payment.
31(bc)Payment of Rs. 2 lakh or above otherwise than by a cheque or bank draft or use of electronic clearing system through a bank account.
31(bb)Receipt of Rs. 2 lakh or above by cheque or bank draft but not being account-payee cheque or account-payee draft.Name, address and PAN of the payer/payee and amount of receipt/payment.
31(bd)Payment of Rs. 2 lakh or above by cheque or bank draft but not being account-payee cheque or account-payee draft.

Refer Section 269 ST of Income Tax Act

Section 269ST says that no person shall receive an amount of Rs. 2 lakhs or more in aggregate:

(i) from a person in a day; or

(ii) in respect of a single transaction; or

(iii) in respect of transactions relating to one event or occasion

from a person otherwise than by account-payee cheque or account-payee bank draft or use of electronic clearing system through a bank account.

For contravention of the provisions of section 269ST the penalty leviable is governed by section 271DA which is equivalent to the sum so transacted.

However, no penalty is imposable if the assessee proves that there were good and sufficient reasons for the contravention. Further, it can be imposed by the Joint Commissioner only.

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