Representation on TAX ACCOUNTING STANDARD (TAS)TAS).pdf · V. P. Verma Ajit Rohira Advisor Y. P. Trivedi K. K. Ramani Office Bearers ... V. R. Ghelani. Draft Tax Accounting Standard

STANDARD (TAS)

THE CHAMBER OF TAX CONSULTANTS

TAX ACCOUNTING

Representationon

THE CHAMBER OF TAX CONSULTANTS

MANAGING COUNCIL2012-2013

PresidentManoj Shah

Vice PresidentYatin Desai

Hon. SecretariesHitesh ShahParas Savla

Hon. TreasurerAvinash Lalwani

Immediate Past PresidentParimal Parikh

MembersAjay Singh

Apurva ShahAshit Shah

Ashok SharmaAtul Bheda

Haresh KeniaHinesh Doshi

Jayant GokhaleK. Gopal

Keshav BhujleKetan Vajani

Kishor VanjaraNinad KarpeVijay Bhatt

Vipul ChoksiVipul Joshi

Yatin Vyavaharkar

Special InviteesBhavesh Vora

Mahendra SanghviSujal ShahV. H. Patil

LAW & REPRESENTATION2012-2013

ChairmanVipul Joshi

Co-ChairmanMahendra Sanghvi

Vice-ChairmanShailesh Bandi

Ex-OfficioManoj ShahYatin Desai

ConvenorsKrish Desai

Amrit Porwal

Past PresidentV. P. VermaAjit Rohira

AdvisorY. P. Trivedi

K. K. Ramani

Office BearersHitesh ShahParas Savla

MG Council MembersApurva Shah

Jayant Gokhale

MembersAtul Suraiya

C. N. VazeDevendra Jain

Durgashankar SharmaKiran Shah

Manish GadiaMayank ShahNitin Potdar

Niranjan DoshiNikita Badheka

Rajen GadaSunil Ramani

Shailesh ShethShilpa Sharma

Sanjay BuchShruti Shah

Sharad AbhyankarV. R. Ghelani

Draft Tax Accounting Standard (TAS)

Page 1 of 21

Representation on Tax Accounting Standard (TAS)

GENERAL PREAMBLE

At the outset, we strongly represent that there is no necessity to introduce TAS at

present because its introduction will result in conflict with the existing Tax Laws,

unsettling the settled positions under, / tax laws, will generate avoidable Tax

litigations. It will also create harrasment of doing unnecessary reconciliation

between Tax Accounting Standard and Books of Account and would also increase the

cost of compliance. However, we highlight some of the points in details in this

regard.

a.) Concept of Materiality not recognised: There are many events in business which

are trivial or insignificant in nature. The cost of recording and reporting such

events cannot be justified by the usefulness of the information derived.

Materiality concept holds that items of small significance need not be given strict

theoretically correct treatment. For example, a stapler costing around Rs.50 may

last for three years; however, the efforts involved in allocating its cost over the

three year period is not worth the benefit that can be derived from this operation.

Since the item obviously is immaterial when related to overall operations, the cost

incurred on it may be treated as the expense of the period in which it is acquired.

Materiality is a subjective concept. Whether financial data is material or not

depends not just on its users but on its purpose. Non recognisation of materiality

concept will increase the cost of compliance and result in harassment to assesses.

b.) Concept of Prudence not recognised: We have to make estimates requiring

judgment to counter the uncertainty. While making judgment we need to be

cautious and prudent. Prudence is a key accounting principle which makes sure

that assets and income are not overstated and liabilities and expenses are not

understated. Ignorance of prudence will result in pre-mature taxation of income

which is not really earned and would result in improper taxation and may create

conflicts with charging sections of Income Tax Act.


Page 2 of 21

GENERAL PREAMBLE

c.) Separate books of Accounts for TAS: Though it has been stated that no separate

books are required to be maintained under income tax laws, implementing the

TAS would be impossible without maintenance of separate books of account

under tax laws, particularly where there are many accounting standards and

conflicting treatments between accounting standards issued under Companies

Act, 1956 / by ICAI and those proposed as TAS under Income Tax Act, 1961.

Reconciling the income as per the books of accounts maintained as per AS (ICAI)

and the income computed as per TAS will become cumbersome exercise. We

recommend harmonization of AS issued by ICAI with TAS proposed to be issued

under Income tax Act, 1961 Further appropriate legislative amendments should

be made to the Act to prevent any scope for leakage of revenue on account of

notification of Accounting Standards issued by the ICAI.

d.) Well settled Judicial Pronouncement: As on today, concerned issues are being

resolved smoothly in absence of TAS by courts. Therefore, TAS will bring

confusions and ambiguity on well settled issues. Further, it will create conflicts on

well settled issues.

e.) Threshold limit for Applicability: Notwithstanding what is stated above, if a TAS is

nonetheless required to be issued, it needs to have a threshold limit for non

applicability, so that smaller assesses are not required to go through such

cumbersome exercise and strict compliance.

f.) Modification in Nomenclature: The nomenclature given as “Tax Accounting

Standard” is not proper and the word “Accounting” is required to be deleted as it

implies that it is required to be accounted, whereas as stated in preamble no

separate books of accounts are required to be maintained and it is applicable to

only computation of total income. Therefore, the nomenclature should not include

the word “Accounting”.


Page 3 of 21

GENERAL PREAMBLE

g.) Non-Applicability: TAS should not be made applicable to Presumptive incomes,

Shipping Companies, Insurance Companies, etc to the extent they are covered by

the special provisions of the Income tax Act.

We are of strong opinion that there is no need for introduction of TAS. Even if one

wants to introduce an uniform mechanism for computation of income, the same

can be introduced through Income Tax Rules. Nonethless, if at all one wants to

introduce TAS then to a criteria as suggested below needs to be specified so as to

avoid process compliance by small tax payers who may not be equipped to that

extent and for whom such compliance may not be economically viable.

Suggested criteria for applicability of Tax Accounting Standards:

(i) Enterprise which are listed on recognized stock exchange whether

in India or outside India

(ii) Enterprise which are in the process of listing their equity or debt

securities as evidenced by Board of Directors in this regard.

(iii) Banks including Co-operative Banks

(iv) Financial Institution, Public Sector Undertaking, enterprise

carrying on insurance business

(v) Assessee’s having turnover of Rs.100 crores or more.

Notwithstanding what is stated above, specific representation along with suggestions

and justification thereof on the each of TAS is made separately hereunder:-


Page 4 of 21

DISCLOSURE OF ACCOUNTING POLICIES

… Sr.

No.

As per the Draft Suggestion Justification

1 As per para 1 This

Accounting

Standard deals with

significant

accounting policies.

Suggested wordings “This

Accounting Standard

deals with disclosure of

significant accounting

policies for the purpose of

tax computation”

This Standard is a disclosure

Standard. As such policies

are governed by the

respective standard and

therefore the suggested

wordings.

2 Wording of para 4

are “ the accounting

policies refer

…….adopted by a

person”

Suggested wording of

para 4 are “ the

accounting policies refer

…….adopted by a person

for the purpose of

computation of income as

per the Tax Accounting

Standards”

TAS are only for specific

purpose of preparation of

tax computation and also

the policies have to be in

line with the Tax Accounting

Standards and therefore

the suggested wordings.

3 The wordings of

para 5 are

“Accounting

policies adopted by

a

person……….profes

sion or vocation”

Suggested wordings are

“Accounting policies

adopted by a personshall

be such as to represent

true and fair view of

income of the business or

profession or income

from other sources as per

TAS”

(1) It does not deal with

Balance Sheet , It only

deals with

computation of

income. Therefore

‘state of affairs’ is not

required.

(2) Profession includes

vocation as defined

under the Act and

hence the word

vocation be deleted

(3) As pre preamble this

Standard is for

computation of

“business income”

and “income from

other sources” and

therefore the

suggested wordings.


Page 5 of 21

DISCLOSURE OF ACCOUNTING POLICIES

4 As per para 5(i) ,

“The treatment and

………not merely by

the legal form”

This clause needs to be

deleted .

To avoide unnecessary

litigations.

5 An Accounting

policy shall not be

changed without

reasonable cause.

An accounting policy shall

not be changed without

reasonable cause.

Grammatical correction.

6 5(ii) marked to

market los……

Marked to market

loss/gain or ……… of such

loss /gain is in ……

In equity , when loss is not

allowed gain should also be

not subject to tax.


Page 6 of 21

VALUATION OF INVENTORIES

Sr.

No.


1. Measurement :

Para 3: Inventories

shall be valued at cost

or net realizable value,

whichever is lower,

except in case of a

service provider, the

inventories of services

shall be valued at cost.

The Sentence shall be

re drafted as

“ Inventories shall be

valued at cost or net

realizable value,

whichever is lower,

except in case of a

service provider, the

inventories for

rendering of services

shall be valued at

cost.

To remove the anomaly for

valuation of inventories for

rendering of services.

2. Cost of Inventories :-

Formulae

Cost of inventories to

be determined on First

in First out, Weighted

Average Cost Formula,

and Retail method.

The technique of

measurement of the

cost of inventories on

the basis of standard

cost to be included.

In certain type of

manufacturing industries,

such as batch production,

it is practically difficult to

measure cost of inventory

on FIFO or Weighted

Average Cost Formulae.

Standard cost method of

measurement should be

permitted which results

approximate to the actual

cost.


Page 7 of 21

EVENT OCCURING AFTER THE PREVIOUS YEAR

Sr. No.


1 Para 3 Adjustment to

assets, liabilities,

income or expense

shall be made for

events

occurring after the

previous year that

provide additional

information materially

affecting the

determination of the

amounts relating to

conditions existing at

the end of the relevant

previous year

Event occurring after

the end of the previous

year that provide

additional information

materially affecting the

determination of the

amounts of asssets ,

liability, income or

expense relating to the

conditions existing at

the end of the relevant

previous year, the

effects of such events be

shall be given in the

comoutation of income

Alternatively

Only adjustments to

income and expenses be

given effect in

computation of income

2 Para 4- Following disclosure shall be made in respect of each class of provision

Following disclosure shall be made in respect of adjustments made to income and expenses for the purpose of computation of income each adjustment.

For event occurring after the end of previous year , the word ‘adjustment’ is more appropriate

3 Para 4(a) a brief

description of the item of income, expense, asset or liability recognized on account of events occurring after balance sheet date (b) amount recognized

(i) A brief description of adjustments affecting item of income, expense, asset or liability on account of events occurring after the end of previous year. (b) amount adjusted

Suggested wordings to have consistency with the title of the Standard.


Page 8 of 21

PRIOR PERIOD ITEMS

Sr.

No.

As per the

Draft

Suggestion Justification

1. It deals with

treatment of

prior period

expense only

– Para 2

AS – 5 deals with prior period

items i.e. income and

expenditure of a prior period.

.

TAS should be comprehensive

and therefore it should cover

treatment for prior period

income.

To be fair to tax payer it

should also consider

disallowance of prior period

item on Net basis, in case of

there is related income

pertaining to prior period

expenses.

For working out taxable

income it may be fair to work

out prior period income and

expenditure on net basis.

2. Para No. 3 (2)

…… unless the

person

proves that

such expense

accrued

during the

said previous

year.

To be modified as follows :

…… unless such expense is

crystallised during the said

previous year.

‘the person proves’ is a harsh

word. If it is concluded that

expense was crystallised

during the previous year, it

should be treated as a current

year expense.

3. Para No. 3 (3) …… accounting estimate or

change in accounting policy

shall not constitute…….

The situation may arise when

there is a prior period charge

due to change in accounting

policy.

4. Para No. 4 Prior Period Items shall be

disclosed with refence to

nature and amount..

As suggested in Sr 1. above prior period item is to be considered and therefore disclosure for the same..

Prior Period items falling in para 3(2) of TAS should only be disclosed as that is relevant.


Page 9 of 21

PRIOR PERIOD ITEMS

There should be some

threshold limit for treating

item as prior period expense.

We suggest threshold limit of

Rs.100,000 or 0.1% of

turnover whichever is lower

may be considered..

To avoid cumbersome exercise

of identifying each and every

prior period expense, this is

suggested.


Page 10 of 21

REVENUE RECOGNITION

Sr.

No.


1. Para No. 1 (2)

It does not deal

with any aspects

of revenue

recognition

which are dealt

with by other

TAS.

Neither this TAS nor any

other TAS covers revenue

arising from insurance

contracts. TAS should

mentioned that revenue

recognition for insurance

contracts will be based on

IRDA Regulation.

This is required to take

care of revenue earned by

insurance companies,

including reliance on

actuarial valuation.

2. Para No. 2 (1) (a)

Definition of

Revenue

It should further add that

‘in an agency relationship,

the revenue is the amount

of commission and not the

gross inflow of cash,

receivable or other

consideration.’

This will cover agents and

brokers which are not

required to book revenue

on a gross basis. This will

have impact on

applicability of tax audit.

3. Para No. 3

….. property in

the goods for a

price or all

significant risk

and reward of

ownership have

been transferred

to the buyer ….

…. Property in the goods for

a consideration and all

significant risk and reward

of ownership have been

transferred to the buyer …..

Price can only be in a

monetary terms while

consideration can also be

in kind.

As per AS – 9 unless significant risk and reward of ownership have been transferred, there is no need to recognise the revenue. If TAS wording is not changed, recognition of revenue will be on transfer of property or transfer of significant risk and reward of ownership whichever is earlier.


Page 11 of 21

REVENUE RECOGNITION

4. Para No. 4

….. revenue

recognition in

respect of such

claim shall be

postponed to the

extent of

uncertainty

involved.

….. revenue recognition in

respect of such claim shall

be postponed to the period

in which ultimate collection

is reasonably certain.

If TAS wordings are

retained it will mean that

revenue may have to be

booked on the basis of

percentage of certainty of

collection. To make it

clear, the wordings

change is required.

The

postponement of

revenue is

restricted only to

two items i.e.

claim for

escalation of

price and export

incentives.

The postponement should

be made applicable to any

revenue where the

collection is not reasonably

certain.

If revenue is booked for

transactions where

collection is not

reasonably certain, it may

amount to recognition of

contingent asset and will

be against the basic

principle of accounting.

5. Para No. 5

It provides that

for booking of

revenue from

service

transactions it is

mandatory to use

proportionate

completion

method.

AS – 9 gives alternative to

either used proportionate

completion method or

completed service contract

method. For certain

services it will be difficult to

apply percentage

completion method, as it

will be difficult to estimate

percentage of work

completed.

For certain service

contracts, TAS should allow

completed service contract

method. Percentage

completion method may be

made mandatory for fixed

price/period contracts,

which can be accounted on

the basis of period elapsed.

Revenue from many

services may be linked to

certain milestone

provided in the contract.

In such cases, it is difficult

to apply percentage of

completion method. For

example, Merchant

banking activity, Repair of

machinery,legal

practioners, consultancy

services etc.


Page 12 of 21

REVENUE RECOGNITION Sr.

No.


6. Para No. 6

….. discount or

premium on debt

securities held is

treated as though

it were accruing

over the period of

maturity.

…… discount or premium on

issuance of debt securities is

treated as if it were accruing

over the period of maturity..

Definition of cost for the

purpose of capital gain needs

to be modified accordingly.

To be inline with the

present scenario

treating discount and

premium on issuance of

debt securities to arrive

at total income.

7. Para No. 9

It is important to clarify as to

where the disclosure is

required, as financial

statements disclosure will be

based on AS.

Disclosure may form

part of form 3CD where

tax audit is applicable.

For other assesses, it

may be exempted.

8. Para No. 9(d)

….. disclosure is

required for the

amount of

retentions.

s.

(I)……. and

recognised

profits (less

recognised

losses)……

The word ‘less’ should be

removed . After the word

profit, word loss needs to be

inserted.

9. Para No. 12 & 13 As per wording given none of the improvements or repairs will get qualified as revenue expenditure. It is important to mention that if there is no increase in the future benefits from the existing assets, “beyond what was originally envisaged”, it shall be charged to revenue.

All repairs will have

future benefit and it will

not be correct to

capitalised all the

expenditure on repairs

and improvements.


Page 13 of 21

REVENUE RECOGNITION

Sr.

No.


10. Para No. 14

…. which becomes

an integral part of

the existing tangible

assets is to be added

to its actual cost.

TAS should specify that it will

be treated as an addition of the

previous year in which such

expenditure is incurred.

In the block concept,

there can not be any

addition to the actual

cost of the original

asset. By the present

wording it may be

construed that

depreciation shall be

calculated

retrospectively.

11. Para No. 15 & 19

There is no need to maintain

tangible fixed assets register,

where concept of block of asset

is involved. It is suggested that

the details mentioned in these

paras may be provided only in

the year of addition to the

fixed assets.

It will be cumbersome

to maintain fixed

assets register for all

the assets in the

concept of block of

asset.

12. Para No. 23

…. where these

conditions are met,

the subsequent

expenditure shall be

added to the actual

cost of the

intangible assets.

Instead of ‘actual cost’, the

word ‘block’ should be

replaced.

To be in line with

Income Tax Law.


Page 14 of 21

ACCOUNTING FOR TANGIBLE FIXED ASSETS

Sr.

No.

As per the

Draft

Suggestion Justification

1. Para No. 2

(1)(a)

…. being land,

building,

machinery,

plant or

furniture held

….

It should be changed to ‘…. being

land, building, furniture & fitting,

machinery and plant, ships held ….’

It should match with

Appendix – I of the

income tax rules

which provides

different blocks. If

the wordings are

not same, it may

create difficulty in

capitalisation.

2. Para No. 2

(1)(b)

Fair Value ….

arm’s length

transaction.

It should be changed to ‘Fair Value

…. arm’s length transaction, who

are fully informed and are not

under any compulsion to transact’.

There is no need to

change definition of

fair value given in

AS – 10.

3. Para No. 6 After the para, following should be

added ‘impact of the above changes

should be adjusted from the

opening block of the respective

asset in the previous year in which

such changes arises’.

Clarification is

required as the

effect is not

expected to be given

retrospectively.

4. Para No. 8 (i)The expenditure incurred upto

start up and commissioning ………

shall be capitalized

exceptexpenditure incurred at the

project stage when there is

abnormal delay in starting of

commercial production.

AS – 10 covers the

same and specifies

that such cost

should be charged

off.


Page 15 of 21

ACCOUNTING FOR TANGIBLE FIXED ASSETS

(ii) The sentence “The expenditure

incurred after the plant has begun

commercial production, i.e.,

production intended for sale or

captive consumption, shall be

treated as revenue

expenditure” needs to be deleted

and instead the following sentence

to be inserted.” The expenditure

after the completion of test run of

the plant shall be treated as

revenue expenditure”

5. Para No. 10 &

11

…. whichever is

lower.

(a) Word Market value needs to

be deleted “

(b)It should be changed to ‘….

whichever is more clearly evident’.

(a) Fair value is

broader term

and already

includes fair

market value

(b) There is no

reason for

accounting at

lower value.

Further, such

accounting

may create

issues in

arriving at

profit or loss

on sale of

asset /

security given

up.


Page 16 of 21

ACCOUNTING FOR TANGIBLE FIXED ASSETS Sr.

No.


6. Para No. 12 & 13 As per wording given

none of the

improvements or

repairs will get qualified

as revenue expenditure.

It is important to

mention that if there is

no increase in the future

benefits from the

existing assets, “beyond

what was originally

envisaged”, it shall be

charged to revenue.

All repairs will have

future benefit and it will

not be correct to

capitalised all the

expenditure on repairs

and improvements.

7. Para No. 14

…. which becomes an

integral part of the

existing tangible

assets is to be added

to its actual cost.

TAS should specify that

it will be treated as an

addition of the previous

year in which such

expenditure is incurred.

In the block concept,

there can not be any

addition to the actual

cost of the original asset.

By the present wording it

may be construed that

depreciation shall be

calculated

retrospectively.

8. Para No. 15 & 19

There is no need to

maintain tangible fixed

assets register, where

concept of block of asset

is involved. It is

suggested that the

details mentioned in

these paras may be

provided only in the

year of addition to the

fixed assets.

It will be cumbersome to

maintain fixed assets

register for all the assets

in the concept of block of

asset.


Page 17 of 21

LEASES

Sr. No.

Issues Justifications

As per draft Suggestions

1.

Para 5 :

Classification of a lease

agreement shall be same

for the lessor and the

lessee and they shall

execute a joint

confirmation regarding

such classification.The

present requirement does

not take care of situation

(a)

TAS should provide for joint

declaration for such

changes

The present

requirement does not

take care of situation

where subsequent to

initial agreement

lease terms are

substantially modified

which may result in

change in original

classification..

2. Para 3(2)

(a) since there is provision

in TAS of joint declaration

for classification of lease ,

this deeming provision is

not required .

Alternatively, the factors

indicated in this para may

be considered while

entering into joint

declaration for lease

agreements.

The deeming

provision for finance

lease may result in a

different

classification than

that of joint

declaration.

3. Under Para 10 of TAS

(LS):

Lease payments under an

operating lease shall be

recognized as an expense

on straight line basis over

the lease term and;

(i) In case of non

cancellable operating

lease, lease payments shall

be recognized as an

expense on straight line

basis over the lease term

It is not correct to apply staright line basis for the full period of lease for cancellable lease.


Page 18 of 21

LEASES

Para 15 of TAS(LS):

Lease income under an

operating lease shall be

recognised as an income

on a straight line basis

over the lease term.

The lease income/

payments in the case of

operating lease is to be

recognised only on a

straight line basis over the

lease term.

However, in cases where

the lease agreement

provides for periodic

increase in lease rentals

over the lease term, as per

the treatment prescribed

under TAS(LS), the

assessee would be

required to offer for tax

such income which has

not even arisen to him in

the given previous year.

Similar issues may arise

where the lease

agreement contains an

escalation or similar

clause.

(ii) In case of cancellable

operating lease, lease

payments shall be

recognized as an expense

on a syatematic basis over

the lease term.

Similar changes are

required under para 15 for

lease income accounting.


Page 19 of 21

LEASES

4. Para 14

The balance of the

receivable at the end of

the lease term shall be

treated as the cost of

acquisition or actual

cost of the asset given

under finance lease at

the time of end of the

lease term.

It is recommended at Para

14 of TAS(LS) be deleted

Since the lessor is

required to record the

finance lease as a sale in

his books at the inception

of the lease itself, the

question of balance, if

any, in the ‘receivable

account’ of the lessor at

the end of the lease term

being regarded as the

‘cost of

acquisition’/’actual cost’

of such leased asset

(which does not at all

appear in the books of

the lessor upon the

inception of the lease)

does not arise.

Accordingly, the

provision contained in

Para 14 of TAS(LS)

cannot be given effect to.

[In fact, when at the

inception of the finance

lease, the lessor is

required to offer the

gains as his income, it is

only fair that any

unrecoverable amount

lying in the ‘receivable

account’ of the lessor at

the end of the lease term

should be allowed as a

loss to the lessor.]


Page 20 of 21

INTANGIBLE ASSETS Sr.

No.


1. Para No. 1

Item no. (i) – goodwill

should be excluded so

that acquired goodwill

can be treated as

intangible assets.

AS – 10 covers acquired

goodwill other than on

merger accounting. If

expenditure is incurred for

purchase of goodwill, it will

be fair to allow the same to

be capitalised.

2. Para No. 2 (1)(a) It should be provided

that computer software

will not be intangible

assets.

It is covered in depreciation

rate - Appendix I as part of

tangible assets.

3. Para No. 2(1)(g) The word ‘systematic’

may be removed from

the definition of

depreciation.

Income Tax Rules provide

specific rate of depreciation

for intangible assets and it

may not be considered as

systematic allocation. In

most of the cases,

systematic allocation will

be in the books of account

and will not match with

Income Tax Rules.

4. Para No. 2(1)(i) . It should be changed to

‘Fair Value …. arm’s

length transaction, who

are fully informed and

are not under any

compulsion to transact’

5. Para No. 2(1)(j)

...net of any

accumulated

depreciation.

It should be changed to

‘… net of depreciation

allowed/allowable in

income tax’.

Required to be in line with

the provision of income tax.


Page 21 of 21

INTANGIBLE ASSETS

6. Para No. 4 Clarification is required

for treatment of

computer software on

stand alone basis.

At present it is getting

covered under Tangible

Fixed Assets.

7. Para No. 5 The reference of goodwill

in the para should be

removed, so that on the

acquired goodwill

depreciation can be

claimed.

Acquired goodwill should

be considered as

depreciable asset.

8. Para No. 14 After the para, following

should be added ‘impact

of the above changes

should be adjusted from

the opening block of the

respective asset in the

previous year in which

such changes arises’.

9. Para No. 23

…. where these

conditions are

met, the

subsequent

expenditure shall

be added to the

actual cost of the

intangible assets.

Instead of ‘actual cost’,

the word ‘block’ should

be replaced.

To be in line with Income

Tax Law.

NOTES

NOTES

NOTES

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Representation on TAX ACCOUNTING STANDARD (TAS)TAS).pdf · V. P. Verma Ajit Rohira Advisor Y. P. Trivedi K. K. Ramani Office Bearers ... V. R. Ghelani. Draft Tax Accounting Standard