Clause 4 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Clause 4 reports whether the assessee is liable to pay indirect tax and the registration or identification numbers allotted. Every registration under each law must be reported, and where a law allots no registration number an identification number such as the IEC is used.
From the ICAI Guidance Note on Tax Audit (Revised 2026), the concluding edition under the Income-tax Act, 1961. For tax years under the Income-tax Act, 2025 the equivalent particular sits in Form No. 26 under rule 47 of the Income-tax Rules, 2026.
What clause 4 asks
"Whether the assessee is liable to pay indirect tax like excise duty, service tax, sales tax, goods and service tax, customs duty, etc. If yes, please furnish the registration number or GST number or any other identification number allotted for the same."
Paragraph 20.4, which deals with clause 4: the auditor is required to examine from appropriate evidence the registration number or any other identification number allotted, where the assessee is liable to pay indirect taxes such as customs duty, excise duty, VAT, sales tax or goods and services tax. Moreover, where multiple registration numbers are available for any indirect tax, the tax auditor should ensure that all such registration numbers are duly reported.
The problem clause 4 creates
Paragraph 20.6 begins from a definitional gap: the term "indirect taxes" is neither defined in the Income-tax Act, 1961 nor under any other law, and the levy of different types of indirect taxes on various transactions may differ from State to State.
The recommended sequence follows from that gap:
- The auditor should obtain from the assessee the list of indirect taxes applicable to him — a management representation.
- Once that representation is obtained, he is required to obtain a copy of the registration certificate clearly mentioning the registration number under the relevant law — for example GSTIN, State Excise, State VAT.
- Where the assessee has multiple registrations for manufacturing units, service units, branches or godowns under the same law, copies of all registration certificates are to be obtained for appropriate disclosure.
- Where the indirect tax law does not require any registration, an appropriate identification number may be reported. The example given: under the Customs Act, 1962 there is no registration number, so a copy of the Importer Exporter Code (IEC) may be obtained and the information furnished accordingly.
Paragraph 20.8 anchors the first step in SA 580, Written Representations. The order matters: without a representation of which laws apply, the auditor has no population to test the certificates against, and an entire State registration can simply be missing from the answer. This is exactly the gap the TAQRB found.
The recommended working paper format
Paragraph 20.7 supplies the format in which the information may be obtained and maintained:
| Sr. No. | Relevant indirect tax law which requires registration | Place of business / profession / service unit for which registration is in place or has been applied for | Registration / identification number |
|---|---|---|---|
| 1 | CGST / SGST | Head office, Maharashtra | GSTIN |
| 2 | CGST / SGST | Branch, Karnataka | GSTIN |
| 3 | State Excise | Manufacturing unit | Excise registration number |
| 4 | Customs Act, 1962 | Importing location | IEC (no registration number under the Act) |
Non-registration
Paragraph 20.8: where the auditor is prima facie of the opinion that an indirect tax law is applicable to the business or profession of the assessee but the assessee is not registered under that law, he should report the same appropriately.
This is a reporting obligation on a matter outside the income-tax law, arrived at on a prima facie view. The auditor is not asked to adjudicate liability under a GST or State excise statute — he is asked to say what he sees.
The TAQRB observations on clause 4
Two are printed in italics under clauses 1 to 8a, and both concern clause 4:
- "Registrations under other indirect tax laws referred to in the CARO Report were not fully reported under this clause."
- "Registration numbers reported under indirect tax laws did not match the PAN reported in Form No. 3CD, without any corresponding qualification or observation in Form No. 3CA/3CB, as applicable."
Both are cross-checks against documents already in the file. A GSTIN embeds the PAN, so a mismatch is visible on the face of the number; and the CARO report of the same company lists statutory dues by law. Neither finding required additional audit work — only comparison.
Worked example
| Fact | Reporting |
|---|---|
| Company with GST registrations in four States | All four GSTINs reported |
| Additional godown registration in one of those States | Reported as well — all registrations under the same law |
| Importer with no customs registration number | IEC reported as the identification number |
| A GSTIN whose embedded PAN differs from clause 3 | Report it and qualify in Para 3 of Form 3CA or Para 5 of Form 3CB |
| Auditor's prima facie view that State excise registration was required but not taken | Report the fact appropriately |
| Assessee's representation lists three laws; the CARO report refers to five | Resolve the difference, extend the certificate request, and report or qualify |
Audit checklist
- Start clause 4 with a written representation under SA 580 listing the indirect tax laws applicable.
- Obtain a registration certificate for every registration, including additional units, branches and godowns.
- Reconcile the list against the CARO report, the GST returns and the statutory dues schedule.
- Check that each registration number's embedded PAN matches the PAN at clause 3.
- Use an identification number such as the IEC where the law allots no registration number.
- Maintain the four-column working paper from paragraph 20.7.
- Report non-registration where a law prima facie applies.
- Report in the format specified by the e-filing utility.
Common mistakes
- Answering clause 4 with the principal GSTIN alone where several registrations exist.
- Skipping the SA 580 representation and working only from the certificates handed over.
- Leaving a PAN mismatch unqualified.
- Leaving clause 4 blank under a law that allots no registration number, instead of giving the IEC.
- Ignoring non-registration because indirect tax is outside the income-tax audit.