Institute of Chartered Accountant of India in their suggestions dated 2nd August, 2018 requested CBDT to implement the changes made in Form 3CD to be implemented from AY 2019-20 for smooth implementation and compliance. It was submitted, “it will cause discrimination between two sets of assessees, those who could file Form 3CD before the cut off date and those who will file after the cut off date. Many audits have started and its not possible to complete it by 19th August, 2018 and moreover the time given to implement new forms is very less which will make it difficult for the tax payers to comply their statutory obligations in a timely and effective manner.” In its letter, the ICAI had submitted various suggestions in the form 3CD. Below is the letter submitted by the ICAI to CBDT.