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Guide3 min readPublished

ICDS versus Ind AS reconciliation items in a tax audit

How a statutory auditor reviews the ICDS-versus-Ind AS reconciliation statement feeding tax audit Form 3CD: the specific line items that diverge, and how to test each one.

Reviewing the ICDS-versus-Ind AS reconciliation means testing each line item where the two frameworks diverge — unrealised foreign exchange gains and losses, the treatment of borrowing costs during a temporary suspension of a qualifying asset's construction, retention money on construction contracts, and the point at which marked-to-market gains and losses on certain financial instruments are recognized for tax purposes — independently against the Ind AS financial statements and the entity's own ICDS computation, rather than accepting the net reconciling figure in Form 3CD as a single checked total.

The repeatable list of divergence items

Common ICDS-versus-Ind AS reconciliation items
ItemInd AS treatmentWhat to test in the reconciliation
Unrealised foreign exchange gain/lossRecognized in profit or loss as the exchange rate movesConfirm the ICDS adjustment reverses the unrealised component correctly, and that it unwinds on actual settlement in the right subsequent year
Borrowing costs during suspension of constructionCapitalisation generally continues through temporary suspension in certain casesConfirm ICDS-based capitalisation period used for tax matches the ICDS rule, not the Ind AS rule, where the two differ
Retention money on construction contractsRecognized based on Ind AS 115 performance obligation satisfactionConfirm retention money is included in contract revenue for tax purposes per the applicable ICDS even where Ind AS 115 timing differs
Marked-to-market loss on financial instrumentsRecognized through profit or loss or OCI depending on classificationConfirm only losses computed per the applicable ICDS method are allowed, and gains are not deferred beyond what ICDS permits
Common ICDS-versus-Ind AS reconciliation items

Testing approach

  • Start from the Ind AS profit before tax and build the ICDS-adjusted computation independently, item by item from the table above, rather than starting from the client's Form 3CD reconciliation and checking its arithmetic.
  • For each adjustment, trace to the underlying ledger or schedule — a forex adjustment, for instance, should trace to the foreign currency monetary item revaluation working, not to a plug figure in the tax computation.
  • Check for consistency year over year in which items are treated as reconciling — an item reconciled last year but silently dropped this year, without a change in the entity's fact pattern, needs explanation.

Regulatory requirement

The Income Computation and Disclosure Standards are notified under section 145(2) of the Income Tax Act and apply for computing income under the heads of profits and gains of business or profession and income from other sources. Confirm the current notified standards and any amendments before relying on a reconciliation item list from a prior year.

This is practical guidance written for audit teams, not an authoritative statement of any standard or statute. Standards, forms and timelines change. Check the current text issued by the ICAI and the relevant authority before relying on anything here in an audit file.

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