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ICDS Applicability Under Section 145(2) — Who Is Covered and What Is Excluded

ICDS applicability is limited to assessees following the mercantile system, and only for computing business or other-sources income, never for maintaining books. It does not...

Published
Updated
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6 min
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6 answered
  • High Complexity
Topic
Income Tax
Published
September 8, 2026
Last updated
Sep 8, 2026
Reading time
6 min
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Last updated: September 2026Verified against: Government sources
Which year this governs

From the ICAI Guidance Note on Tax Audit (Revised 2026), the concluding edition under the Income-tax Act, 1961. The ICDS are notified under section 145(2) of that Act; for tax years governed by the Income-tax Act, 2025, the standards notified under the corresponding provision must be applied, and the audit report becomes Form No. 26 under rule 47 of the Income-tax Rules, 2026.

The ICDS applicability rules

Paragraph 25.8: in exercise of the powers in section 145(2), the Central Government has notified the ICDS to be followed by all assessees following the mercantile system of accounting, for computing income chargeable under "Profits and gains of business or profession" or "Income from other sources".

Paragraph 25.9 then sets the boundaries, and this list is the practical statement of ICDS applicability:

QuestionAnswer
Cash method assessees?ICDS does not apply
Maintenance of books of account?Not applicable — each ICDS says so in its preamble, and this holds even under the mercantile system
Book profit under section 115JB (MAT)?Does not apply, because ICDS applies to computation under the regular provisions
AMT under section 115JC?Applies — AMT is computed on adjusted total income derived by making specified adjustments to total income computed under the regular provisions
Banks, NBFCs, insurance companies, power sector?The general provisions apply to all persons unless there are sector-specific provisions in the ICDS or in the Act
Gross-basis computations — interest, royalty, fees for technical services under section 115A?Applies, for arriving at the amount chargeable to tax

So far, 10 ICDS have been issued by the Government, and CBDT has issued clarifications through Circular No. 10/2017 dated 23 March 2017.

The MAT/AMT split is the counter-intuitive one

The same set of standards is excluded from the section 115JB book profit computation and included in the section 115JC AMT computation. The reason is structural: book profit starts from the profit and loss account, which ICDS never touches; adjusted total income starts from total income under the regular provisions, which ICDS does affect. A company computing both figures must therefore carry the ICDS adjustments into one and keep them out of the other.

The ten standards

Paragraph 25.9 sets out what each covers:

StandardScope note from the Guidance Note
IAccounting PoliciesApplication of significant accounting assumptions and policies in computing income. Financial statements reflect the state of financial affairs and form the base for computing taxable income
IIValuation of InventoriesThe concept and definition of "inventory" in para 2(1) contemplates business; even the sub-clause on materials and supplies consumed in production or in rendering services contemplates the existence of business
IIIConstruction ContractsA contract negotiated for construction of an asset or combination of assets; where activity continues beyond a year, whether the contractor is taxed on completion or proportionately over the years
IVRevenue RecognitionBased on AS 9; some AS 9 principles are adopted, but there are significant differences between the ICDS and AS 9
VTangible Fixed AssetsLand, building, machinery, plant or furniture held with the intention of being used to produce or provide goods or services, and not held for sale in the normal course
VIEffects of Changes in Foreign Exchange RatesCorresponds to AS 11 and to Ind AS 21 notified under the Companies (Indian Accounting Standards) Rules, 2015
VIIGovernment GrantsMeaning, scope, forms, point of taxation and disclosure. The Finance Act, 2015 expanded "income" to include all government grants save asset-specific grants; the ICDS guides year of taxation or capitalisation, refund mechanism, point of recognition and treatment of grants for a group of assets
VIIISecuritiesPart A — securities held as stock-in-trade, but not securities held by insurance businesses, mutual funds or venture capital funds, and not those held by banks and public financial institutions. Part B carries specific provisions for scheduled banks and public financial institutions
IXBorrowing CostsRelevant for section 36(1)(iii), for Explanation 8 to section 43(1) on interest that cannot be capitalised, and for section 57(iii) on deductibility of interest under income from other sources
XProvisions, Contingent Liabilities and Contingent AssetsExcludes items arising from financial instruments, executory contracts and insurance business contracts with policyholders — and excludes financial instrument transactions whether held as investments or as stock-in-trade

Where to read further

Paragraph 25.13 points to two sources: the ICDS notified by the CBDT under section 145(2), and ICAI's Direct Taxes Committee publication "Technical Guide on Income Computation and Disclosure Standards", issued in July 2017.

Worked example

AssesseeICDS applicability
Proprietor on the cash systemNot applicable. Clause 13(d) is answered "No"
Firm on the mercantile systemApplies to business and other-sources income; not to its books
Company computing section 115JB book profitICDS adjustments excluded from book profit
LLP computing AMT under section 115JCICDS adjustments flow through into adjusted total income
Scheduled bank holding securitiesPart B of ICDS VIII, not Part A; measurement per RBI guidelines under section 145A
Non-resident with royalty taxed on a gross basis under section 115AICDS applies for arriving at the amount chargeable

Audit checklist

  • Establish the method of accounting first — the whole question of ICDS applicability turns on it.
  • Record the ICDS applicability conclusion in the working papers before answering clause 13(d).
  • Confirm the ICDS adjustments were made in the computation, not in the books.
  • Keep ICDS adjustments out of the section 115JB book profit and inside the section 115JC AMT computation.
  • For banks, NBFCs, insurers and the power sector, check for sector-specific provisions before applying the general ones.
  • Apply ICDS to gross-basis section 115A computations.
  • Use Part A or Part B of ICDS VIII according to the entity type.
  • Read Circular No. 10/2017 and ICAI's Technical Guide on ICDS.

Common mistakes

  • Applying ICDS to a cash-basis assessee.
  • Restating the books for an ICDS difference.
  • Carrying ICDS adjustments into section 115JB book profit.
  • Omitting them from the section 115JC AMT computation.
  • Applying Part A of ICDS VIII to a scheduled bank or public financial institution.
Quick recapKey facts & short answers

Key Facts About ICDS Applicability

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

Who must follow ICDS?

All assessees following the mercantile system of accounting, for computing income chargeable under profits and gains of business or profession or income from other sources.

Does ICDS apply to the cash method?

No. ICDS does not apply to assessees following the cash method of accounting.

What is not written down will be remembered differently by everyone involved.

— TaxClue Compliance Desk

ICDS Applicability: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

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Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

People also ask

Questions, answered

Short, direct answers to the 6 questions readers ask most on this topic.

All assessees following the mercantile system of accounting, for computing income chargeable under profits and gains of business or profession or income from other sources.

No. ICDS does not apply to assessees following the cash method of accounting.

No. Each ICDS states in its preamble that it is applicable for computation of income and not for the purpose of maintenance of books of account.

ICDS does not apply for computation of book profit under section 115JB. It does apply for computing AMT under section 115JC, because AMT is computed on adjusted total income derived from total income computed under the regular provisions.

Yes. The general provisions apply to all persons — banks, non-banking financial institutions, insurance companies, the power sector and others — unless there are sector-specific provisions in the ICDS or in the Act.

Yes. It applies for computation of income on a gross basis, such as interest, royalty and fees for technical services under section 115A, for arriving at the amount chargeable to tax.