Therajpicz: Inclusion of Company Secretaries in the Definition of "Accountant" under the Income-Tax Bill, 2025


The Institute of Company Secretaries of India (ICSI) has made a significant appeal to the Indian government, urging the inclusion of Company Secretaries (CS) within the definition of "Accountant" under Section 515(3)(b) of The Income-Tax Bill, 2025. This move aims to recognize the expertise of Company Secretaries in taxation and compliance, ensuring a broader and more competitive tax ecosystem in India.

Why is this Inclusion Important?

  1. Expanding the Pool of Tax Professionals
    The taxation landscape in India has been undergoing rapid changes, and there is a growing need for professionals who can help businesses comply with tax laws effectively. Recognizing Company Secretaries as "Accountants" would expand the pool of qualified professionals, reducing dependency on a single profession and ensuring better compliance, especially in Tier 2 and Tier 3 cities.

  2. Expertise in Taxation and Compliance
    Company Secretaries undergo extensive training in taxation, corporate governance, and financial laws. The CS curriculum includes direct and indirect tax laws, corporate tax planning, and financial accounting, equipping them with the necessary knowledge to handle tax-related matters efficiently.

  3. Enhancing Ease of Doing Business
    By including CS professionals in the definition of "Accountant," small and medium enterprises (SMEs) will have a wider and more cost-effective choice of tax professionals. This will contribute to India's vision of improving the ease of doing business and simplifying tax compliance.

Parliamentary Support and Past Recommendations

The demand for recognizing CS professionals in taxation has been long-standing. Several Parliamentary Standing Committees have previously recommended widening the scope of the definition of "Accountant" to include Company Secretaries:

  • 49th Report of the Parliamentary Standing Committee on Finance (2012) suggested that including CS professionals would provide SMEs with cost-effective tax solutions.
  • Direct Tax Code 2013 (DTC) explicitly included Company Secretaries within the definition of "Accountant."
  • 122nd Report on Ease of Doing Business (2015) recommended that the Income-Tax Act should recognize Company Secretaries and other professionals for tax representation and compliance.

Recognitions Already Available to Company Secretaries

Company Secretaries in practice have already been authorized to conduct various certification and audit services under multiple laws, such as:

  • Internal audits under the Companies Act, 2013
  • Tax-related certifications under GST laws
  • Compliance audits under SEBI regulations
  • Representation rights before various regulatory bodies

These existing authorizations highlight the deep involvement of CS professionals in taxation and governance matters.

Conclusion

Recognizing Company Secretaries as "Accountants" under the Income-Tax Bill, 2025, is a logical and necessary step toward strengthening India’s tax ecosystem. It will ensure timely tax filings, reduce compliance bottlenecks, and empower businesses with more professional choices.

The ICSI has made a strong case for this inclusion, and now it is up to policymakers to take this progressive step toward a more inclusive and efficient tax framework.

What are your thoughts on this proposal? Do you think Company Secretaries should be included in the definition of "Accountant"? Let us know in the comments!

General Questions

1. What is the key request made by ICSI in its representation on the Income-Tax Bill, 2025?
📌 The Institute of Company Secretaries of India (ICSI) has requested the inclusion of Company Secretaries (CS) in the definition of "Accountant" under Section 515(3)(b) of The Income-Tax Bill, 2025.

2. Why does ICSI seek this inclusion?
📌 ICSI argues that Company Secretaries are well-trained in taxation and compliance matters, and their inclusion will help expand the pool of tax professionals in India, improving tax governance and compliance efficiency.

3. Where can I find the official notification regarding this request?
📌 The official ICSI representation can be accessed here: ICSI Representation on Income-Tax Bill, 2025.

4. What is Section 515(3)(b) of the Income-Tax Bill, 2025?
📌 This section defines the term "Accountant" and currently includes Chartered Accountants (CAs) but does not explicitly recognize Company Secretaries (CS) for tax-related matters.


Significance of the Proposal

5. How will the inclusion of Company Secretaries in the definition of "Accountant" benefit businesses?
📌 It will provide businesses, especially MSMEs, with a wider choice of tax professionals, reducing compliance delays and bottlenecks.

6. How can this change improve India’s taxation system?
📌 It will ensure timely tax filings, reduce the need for repeated tax extensions, and promote competition among tax professionals, leading to better service quality.

7. How does this proposal align with India's goal of becoming a $5 trillion economy?
📌 By expanding the availability of skilled tax professionals, it will improve tax compliance, reduce legal disputes, and create a more business-friendly environment.

8. How does this inclusion support the ease of doing business?
📌 It allows businesses to engage competent professionals at competitive rates, reducing tax-related complexities and improving compliance efficiency.


Expertise of Company Secretaries in Taxation

9. Do Company Secretaries study taxation as part of their curriculum?
📌 Yes, the CS curriculum includes subjects like Corporate Tax Planning, Direct and Indirect Taxation, and Financial Accounting, equipping them with strong taxation knowledge.

10. What certifications do CS professionals hold in taxation?
📌 CS professionals can pursue specialized certifications like:

  • Post Membership Qualification (PMQ) Course on Direct Taxes
  • Certificate Course on GST
  • Certificate Course on Corporate Tax & VAT in UAE

11. Are CS professionals already authorized to conduct any tax-related audits?
📌 Yes, CS professionals are authorized to conduct various audits, including internal audits, secretarial audits, and compliance audits under SEBI and GST laws.


Parliamentary Support & Past Recommendations

12. Has the government considered this proposal before?
📌 Yes, several Parliamentary Standing Committees have recommended including CS professionals in the definition of "Accountant."

13. What did the 49th Report of the Parliamentary Standing Committee on Finance (2012) say about this?
📌 It suggested including CS professionals to provide MSMEs with more cost-effective tax compliance options.

14. What was the stance of the Direct Tax Code, 2013 (DTC) on this matter?
📌 The DTC 2013 explicitly included Company Secretaries, Cost Accountants, and other professionals in the definition of "Accountant."

15. What recommendation was made in the 122nd Report on Ease of Doing Business (2015)?
📌 It recommended expanding the definition of "Accountant" to include non-Chartered Accountants like Company Secretaries and Cost Accountants.


Comparison with Other Professions

16. How does the role of a Company Secretary differ from that of a Chartered Accountant (CA) in taxation?
📌 While CAs specialize in auditing and accounting, CS professionals focus on corporate law, governance, and taxation compliance, making them equally valuable in tax matters.

17. Are CS professionals allowed to represent clients in tax matters?
📌 Yes, CS professionals can act as authorized representatives under various laws, including GST and SEBI regulations.

18. What other recognitions do CS professionals hold in financial compliance?
📌 CS professionals are recognized as:

  • Registered Valuers under the Companies (Registered Valuers and Valuation) Rules, 2017
  • Internal auditors under Section 138 of the Companies Act, 2013
  • Compliance auditors for SEBI, RBI, and IFSCA regulations

Future Implications

19. What will be the impact if CS professionals are included in the definition of "Accountant"?
📌 It will create a more competitive tax ecosystem, improve compliance efficiency, and help businesses access tax professionals more easily, especially in smaller cities.

20. What should be the next step for implementing this change?
📌 The government should amend the Income-Tax Bill, 2025, based on ICSI's representation and the past recommendations of Parliamentary Committees.


Final Thoughts

ICSI’s demand for recognizing Company Secretaries as "Accountants" under tax laws is a crucial step toward strengthening India's taxation framework. Given their expertise in corporate laws, taxation, and compliance, CS professionals can significantly contribute to improving the efficiency of tax governance.

For more details, check out the official ICSI notification here:
📢 ICSI Representation on Income-Tax Bill, 2025

What’s your take on this proposal? Should CS professionals be recognized under tax laws? Share your thoughts in the comments! 🚀

The inclusion of Company Secretaries in the definition of "Accountant" under the Income-Tax Bill, 2025 is a crucial development that aligns with multiple subjects in both CS Executive and CS Professional programs. There is a strong possibility that this topic could appear in exams, especially in subjects related to taxation, corporate governance, and regulatory frameworks.

CS Executive (New Syllabus)

This topic is relevant for:

  1. Tax Laws & Practice (Group 2, Paper 7)

    • Direct Tax Laws
    • Income Tax Act, 1961
    • GST Provisions & Compliance
    • Role of Professionals in Taxation
  2. Corporate & Economic Laws (Group 1, Paper 2)

    • Understanding the role of professionals in compliance
    • Regulatory framework under the Companies Act, 2013
  3. Corporate Accounting & Financial Management (Group 1, Paper 4)

    • Accounting and taxation practices

CS Professional (New Syllabus)

This topic is crucial in:

  1. Corporate Funding & Listings in Stock Exchanges (Group 1, Paper 3)

    • Understanding financial compliance and certifications required by professionals
  2. Economic, Business & Commercial Laws (Group 2, Paper 5)

    • Role of Company Secretaries in taxation laws and regulatory affairs
  3. Goods & Services Tax (GST) & Corporate Tax Planning (Group 2, Paper 7.2)

    • Direct and Indirect Taxation
    • Tax Planning Strategies
    • Role of CS in Tax Compliance

Possibility of Exam Questions

  • MCQs & Case-Based Questions related to:
    • Definition of "Accountant" under Income-Tax Bill, 2025
    • Role of CS in tax compliance
    • Parliamentary recommendations on CS in taxation
  • Descriptive Questions:
    • "Discuss the significance of including CS in the definition of Accountant under the Income-Tax Bill, 2025."
    • "Explain the role of CS professionals in taxation and why they should be considered under the new Income-Tax Bill."

Final Thoughts

This is an important development for CS students, especially those appearing for the Tax Laws & GST papers. Staying updated on this topic can help in exam preparation, professional practice, and corporate governance roles.

1. What is the key proposal made by ICSI regarding the Income-Tax Bill, 2025?

📌 Answer: ICSI has proposed the inclusion of Company Secretaries (CS) in the definition of "Accountant" under Section 515(3)(b) of The Income-Tax Bill, 2025. This would allow CS professionals to provide tax compliance and audit-related services.


2. Under which section of the Income-Tax Bill, 2025, does ICSI seek recognition for Company Secretaries?

📌 Answer: ICSI seeks inclusion under Section 515(3)(b) of The Income-Tax Bill, 2025, which defines the term "Accountant."


3. Why is ICSI demanding the inclusion of CS professionals in tax practice?

📌 Answer: ICSI argues that Company Secretaries:
✅ Have expertise in taxation, corporate laws, and compliance
✅ Can help businesses, especially MSMEs, with cost-effective tax compliance
✅ Can expand the availability of qualified professionals in taxation


4. How does the inclusion of CS professionals in the definition of "Accountant" benefit the taxation system?

📌 Answer:

  • It ensures timely tax filings, reducing compliance delays.
  • It prevents dependence on a single profession (Chartered Accountants).
  • It strengthens tax governance by allowing more professionals to contribute.

5. What recommendations have been made by Parliamentary Committees regarding this inclusion?

📌 Answer:

  1. 49th Report of the Standing Committee on Finance (2012) – Recommended widening the definition of "Accountant" to include CS professionals.
  2. Direct Tax Code, 2013 (DTC) – Included CS, Cost Accountants, and other professionals in the definition of "Accountant."
  3. 122nd Report on Ease of Doing Business (2015) – Suggested expanding the scope of "Accountant" to non-CAs like CS, Cost Accountants, and legal experts.

6. How does the recognition of CS professionals align with India's economic growth plans?

📌 Answer: India aims to become a $5 trillion economy by 2027. Expanding the tax professional pool will:

  • Improve compliance efficiency
  • Reduce tax disputes
  • Boost the ease of doing business

7. In which CS subjects is this topic relevant for exam purposes?

📌 Answer:
📖 CS Executive:

  • Tax Laws & Practice (Paper 7)
  • Corporate & Economic Laws (Paper 2)

📖 CS Professional:

  • Goods & Services Tax (GST) & Corporate Tax Planning (Paper 7.2)
  • Economic, Business & Commercial Laws (Paper 5)

8. What tax-related roles can CS professionals currently perform?

📌 Answer: CS professionals are authorized to:
✅ Conduct GST audits
✅ Certify corporate tax compliance
✅ Provide legal opinions on taxation matters
✅ Represent clients before tax authorities


9. What are the arguments against the inclusion of CS in the definition of "Accountant"?

📌 Answer: Critics argue that:
❌ CS professionals lack auditing expertise compared to CAs.
❌ The move could create overlap in professional roles.
❌ Tax laws require specialized accounting knowledge, which CAs primarily handle.


10. How can this proposal impact CS students and professionals in the future?

📌 Answer:
🎯 For CS Students – More focus on taxation in the CS curriculum and higher demand for tax professionals.
🎯 For CS Professionals – Expanded career opportunities in tax consultancy, audits, and compliance services.


Final Thoughts

This topic is highly relevant for CS students preparing for taxation and compliance-related subjects. Understanding this issue can help in both exams and real-world professional practice.

Notes on Inclusion of Company Secretaries in the Definition of "Accountant" under the Income-Tax Bill, 2025

This topic is crucial for CS Executive & CS Professional students, particularly in Tax Laws, Corporate & Economic Laws, and GST & Corporate Tax Planning subjects.


1️⃣ Introduction

  • The Institute of Company Secretaries of India (ICSI) has requested the government to include Company Secretaries (CS) in the definition of "Accountant" under Section 515(3)(b) of the Income-Tax Bill, 2025.
  • This will allow CS professionals to provide tax compliance and audit-related services, improving the taxation ecosystem in India.

📢 Official Notification: ICSI Representation on Income-Tax Bill, 2025


2️⃣ What is Section 515(3)(b) of the Income-Tax Bill, 2025?

  • This section defines the term "Accountant", currently limited to Chartered Accountants (CAs) under the Chartered Accountants Act, 1949.
  • ICSI proposes that CS professionals should also be included in this definition to allow them to perform tax-related functions.

3️⃣ Why is ICSI Seeking Inclusion of CS Professionals?

ICSI argues that:
✅ CS professionals have expertise in taxation, compliance, and corporate laws.
✅ Expanding the definition will increase the availability of tax professionals.
✅ This move supports MSMEs and improves the Ease of Doing Business.

🔹 Current Problem: Dependence on a single profession (CAs) creates compliance delays and bottlenecks.
🔹 Solution: Including CS professionals will reduce this dependency and increase efficiency in tax filings.


4️⃣ Benefits of Including CS in the Definition of "Accountant"

BenefitImpact
More professionals available for tax complianceFaster and smoother tax filings
Better compliance in Tier 2 & 3 citiesHelps small businesses & startups
Strengthening of tax governanceReduces tax evasion and delays
Boost to India’s $5 trillion economy goalImproves Ease of Doing Business
Wider scope for CS professionalsMore career opportunities in taxation

5️⃣ Parliamentary Support & Past Recommendations

This demand has been supported by several Parliamentary Committees:

📌 49th Report of the Standing Committee on Finance (2012)
🔹 Suggested widening the definition of "Accountant" to include CS professionals.

📌 Direct Tax Code, 2013 (DTC)
🔹 Defined "Accountant" to include CS, Cost Accountants, and other professionals.

📌 122nd Report on Ease of Doing Business (2015)
🔹 Recommended allowing Company Secretaries to represent businesses in tax matters.


6️⃣ Existing Taxation & Compliance Roles of CS Professionals

Currently, CS professionals are already authorized for multiple financial compliance roles:

GST Law – Can appear as authorized representatives.
Companies Act, 2013 – Allowed to conduct Internal Audits.
SEBI & RBI Regulations – Provide compliance certifications.
Registered Valuers (Companies Act, 2013) – Valuation of financial assets.
Foreign Exchange & Customs Laws – Assist in compliance & regulatory filings.


7️⃣ How Does This Proposal Help India’s Economy?

  • India aims to become a $5 trillion economy by 2027.
  • More tax professionals = Improved tax compliance & reduced disputes.
  • Encourages ease of doing business by ensuring smooth tax processes.

8️⃣ Relevant CS Subjects for Exam Preparation

📖 CS Executive
🔹 Tax Laws & Practice (Paper 7)
🔹 Corporate & Economic Laws (Paper 2)
🔹 Corporate Accounting & Financial Management (Paper 4)

📖 CS Professional
🔹 GST & Corporate Tax Planning (Paper 7.2)
🔹 Economic, Business & Commercial Laws (Paper 5)

📌 Possible Exam Questions

  • MCQs & Case-Based Questions: On tax compliance, Section 515(3)(b), and CS roles in taxation.
  • Descriptive Questions: Discussing the importance of CS professionals in tax governance.

9️⃣ Counterarguments Against This Inclusion

Some argue that:
❌ CS professionals lack auditing expertise compared to CAs.
❌ The move could create overlaps in professional roles.
❌ Tax laws require specialized accounting knowledge, traditionally handled by Chartered Accountants.

However, ICSI counters that CS professionals already handle complex financial regulations and audits under various laws.


🔟 Conclusion

📌 Including CS professionals in the definition of "Accountant" is a necessary reform to improve tax governance and compliance in India.
📌 This will empower businesses, reduce compliance burdens, and expand career opportunities for CS professionals.


💡 Key Takeaways for CS Students & Professionals

Stay updated with taxation and compliance laws.
This topic is highly relevant for CS exams, especially in taxation and corporate laws.
If implemented, this will open up new career paths for CS professionals in taxation and financial compliance.


📢 Important Resource

📌 ICSI Representation on Income-Tax Bill, 2025

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