ICDS I – Accounting Policies

ICDS I - Accounting Policies | Educational Resource

ICDS I – Accounting Policies

Income Computation and Disclosure Standards

1. INTRODUCTION TO ICDS

1.1 What are Income Computation and Disclosure Standards (ICDS)?

Income Computation and Disclosure Standards (ICDS) were notified by the Central Board of Direct Taxes (CBDT) under Section 145(2) of the Income Tax Act, 1961. These standards were introduced to bring uniformity in the computation of taxable income and reduce disputes between taxpayers and tax authorities.

1.2 Legal Framework

  • Notification Number: 87/2016 dated September 29, 2016
  • Effective From: Assessment Year 2017-18 onwards
  • Applicable Period: Financial Year 2016-17 and subsequent years
  • Legal Authority: Section 145(2) of Income Tax Act, 1961

1.3 List of 10 ICDS

ICDS No. Title Corresponding AS
ICDS I Accounting Policies AS-1
ICDS II Valuation of Inventories AS-2
ICDS III Construction Contracts AS-7
ICDS IV Revenue Recognition AS-9
ICDS V Tangible Fixed Assets AS-10
ICDS VI Effects of Changes in Foreign Exchange Rates AS-11
ICDS VII Government Grants AS-12
ICDS VIII Securities AS-13
ICDS IX Borrowing Costs AS-16
ICDS X Provisions, Contingent Liabilities and Contingent Assets AS-29

2. OVERVIEW OF ICDS I – ACCOUNTING POLICIES

2.1 Definition

ICDS I deals with significant accounting policies that govern the computation of income chargeable to tax under the heads:

  • Profits and Gains of Business or Profession
  • Income from Other Sources

2.2 Purpose and Objective

Primary Objectives:

  • To ensure consistency in the application of accounting policies
  • To bring uniformity in income computation across assessees
  • To reduce litigation between taxpayers and tax authorities
  • To provide clarity on income recognition principles
  • To align tax computation with business realities

2.3 Key Features

Feature Description
Purpose For computation of income only, NOT for maintenance of books
Priority Income Tax Act prevails over ICDS in case of conflict
Scope Covers significant accounting policies and their disclosure
Prudence Prudence concept NOT applicable unless specifically provided
Materiality Materiality concept NOT specifically mentioned in ICDS I

3. APPLICABILITY OF ICDS I

3.1 Who Must Follow ICDS?

ICDS applies to:

  • All assessees following mercantile system of accounting
  • Corporate entities (Companies, LLPs)
  • Non-corporate entities (Partnership firms, Proprietorships subject to tax audit)
  • Trusts and AOPs having business income

3.2 Exemptions

ICDS does NOT apply to:

  • Individuals and HUFs not required to get accounts audited under Section 44AB
  • Cash basis assessees (following cash system of accounting)
  • Computation of Minimum Alternate Tax (MAT) under Section 115JB

3.3 Applicability Chart

Type of Assessee Accounting Method Audit u/s 44AB ICDS Applicable?
Company Mercantile Yes YES
Partnership Firm Mercantile Yes YES
Individual (Business) Mercantile Yes YES
Individual (Small Business) Mercantile No NO
HUF (Business) Mercantile No NO
Any Assessee Cash N/A NO

4. KEY CONCEPTS IN ICDS I

4.1 What are Accounting Policies?

Accounting Policies are the specific accounting principles and methods of applying those principles adopted by an enterprise in the preparation and presentation of financial statements.

4.2 Significant Accounting Policies

Factors determining significance:

  • Magnitude of impact on financial statements
  • Influence on decisions of users of financial statements
  • Industry-specific practices
  • Nature of business operations
  • Peculiar circumstances of the enterprise

4.3 Substance Over Form

Definition: The accounting treatment and presentation of transactions and events should be governed by their substance and economic reality, not merely by their legal form.

Example:

A company sells an asset but retains substantially all risks and rewards of ownership through a buyback agreement. Under substance over form, this should NOT be treated as a sale but as a financing transaction, regardless of the legal documentation.

4.4 Prudence - Key Difference

Aspect AS-1 (Accounting Standard) ICDS I
Prudence Concept ✓ Applicable - Recognize losses when probable ✗ NOT applicable unless specifically provided in ICDS
Mark-to-Market Losses Can be recognized based on prudence NOT recognized unless other ICDS specifically provides
Expected Losses Can be provided for NOT recognized unless specific ICDS provision
Unrealized Gains Generally not recognized Same principle - mutatis mutandis applies to gains

4.5 Change in Accounting Policy

An accounting policy shall not be changed without reasonable cause.

Reasonable Cause includes:

  • Change in statutory requirements
  • Change in accounting standards or ICDS
  • Better presentation of financial information
  • More appropriate reflection of business operations
  • Change in nature of business

5. FUNDAMENTAL ACCOUNTING PRINCIPLES

5.1 Three Pillars of Accounting

5.1.1 GOING CONCERN

Definition: The enterprise is normally viewed as a going concern, that is, as continuing in operation for the foreseeable future.

Implications:

  • Assets are recorded at cost, not at liquidation value
  • Depreciation is charged over useful life of assets
  • No intention or necessity of liquidation or curtailing operations
  • Financial statements prepared on continuity assumption

Example:

ABC Ltd. purchased machinery for ₹10,00,000 with a useful life of 10 years. Under going concern assumption, depreciation is charged at ₹1,00,000 per year. If the company were not a going concern, the machinery would be valued at its realizable value (say ₹3,00,000), which could be much lower.

Disclosure Requirement: If the going concern assumption is not followed, the fact must be disclosed.

5.1.2 CONSISTENCY

Definition: Accounting policies should be consistent from one period to another to ensure comparability of financial statements.

Implications:

  • Same accounting policies to be followed period after period
  • Enables meaningful comparison over time
  • Changes allowed only with reasonable cause
  • Effect of change must be quantified and disclosed

Example:

XYZ Ltd. has been using Written Down Value (WDV) method for depreciation. In FY 2023-24, it cannot suddenly switch to Straight Line Method (SLM) without reasonable cause. If changed, the company must:

  • Disclose the change in accounting policy
  • State the reason for change
  • Quantify the effect on current year's profit (e.g., profit increased by ₹2,50,000 due to change)
Year Method Depreciation Impact
2022-23 WDV @ 15% ₹1,50,000 -
2023-24 (with change) SLM ₹1,00,000 Profit ↑ by ₹50,000

5.1.3 ACCRUAL

Definition: Revenues and costs are recognized when they are earned or incurred (not when money is received or paid) and recorded in the financial statements of the periods to which they relate.

Key Points:

  • Income is recognized when it accrues (right to receive arises)
  • Expenses are recognized when they are incurred
  • Recognition is independent of actual receipt/payment
  • Matching principle - expenses matched with related revenues

Example - Revenue Recognition:

Date Event Recognition
01-Jan-2024 Goods sold to customer, Invoice raised for ₹5,00,000 Income recognized: ₹5,00,000
15-Jan-2024 Customer makes payment Cash received (no additional income)

Example - Expense Recognition:

Date Event Recognition
20-Mar-2024 Electricity consumed in March, Bill for ₹50,000 received on 05-Apr-2024 Expense recognized in March: ₹50,000
10-Apr-2024 Payment made Cash paid (no additional expense)

6. ICDS I VS AS-1 COMPARISON

6.1 Detailed Comparison Table

Sr. No. Particulars AS-1 (Accounting Standard) ICDS I
1 Purpose For preparation and presentation of financial statements For computation of taxable income only, NOT for book maintenance
2 Applicability All enterprises preparing financial statements Only for computing income under business/profession or other sources
3 Prudence ✓ Specifically mentioned and applicable ✗ NOT mentioned; not applicable unless ICDS specifically provides
4 Materiality ✓ Specifically considered as an important factor ✗ NOT specifically mentioned
5 Substance over Form ✓ Applicable ✓ Applicable (Common feature)
6 Going Concern ✓ Fundamental assumption ✓ Fundamental assumption (Common feature)
7 Consistency ✓ Fundamental assumption ✓ Fundamental assumption (Common feature)
8 Accrual ✓ Fundamental assumption ✓ Fundamental assumption (Common feature)
9 Mark-to-Market Losses May be recognized based on prudence Shall NOT be recognized unless specifically provided in ICDS
10 Expected Losses Can be provided for under prudence Shall NOT be recognized unless specifically provided in ICDS
11 Change in Policy Change allowed with justification Change NOT allowed without "reasonable cause"
12 Disclosure Requirements Detailed disclosure requirements for financial reporting Disclosure for tax computation purposes
13 Legal Standing Recommendatory (mandatory for companies under Companies Act) Mandatory for tax computation for specified assessees
14 Conflict Resolution Companies Act provisions prevail for companies Income Tax Act provisions prevail over ICDS

6.2 Key Takeaways

Similarities:

  • Both recognize Substance over Form
  • Both follow Going Concern, Consistency, and Accrual principles
  • Both require disclosure of significant accounting policies

Critical Differences:

  • Prudence: The most significant difference - AS-1 follows prudence, ICDS I does not
  • Purpose: AS-1 for financial reporting, ICDS I only for tax computation
  • Materiality: Not emphasized in ICDS I
  • Expected/MTM Losses: Treatment differs significantly

7. DISCLOSURE REQUIREMENTS

7.1 Mandatory Disclosures

Under ICDS I, the following disclosures are required:

1. Significant Accounting Policies

All significant accounting policies adopted for computing income must be disclosed, including:

  • Revenue recognition policy
  • Depreciation method and rates
  • Inventory valuation method
  • Foreign exchange transactions treatment
  • Treatment of government grants
  • Borrowing cost capitalization policy

2. Change in Accounting Policy

If any accounting policy is changed during the year:

  • Nature of change must be disclosed
  • Reason for change ("reasonable cause")
  • Amount by which any item is affected by such change
  • Impact on taxable income (to the extent ascertainable)

3. Deviation from Fundamental Assumptions

If any of the three fundamental assumptions (Going Concern, Consistency, Accrual) is NOT followed:

  • The fact must be disclosed
  • Reason for such deviation
  • Financial impact of the deviation

7.2 Disclosure in Tax Audit Report

Form 3CD has been revised to include disclosures relating to ICDS:

Clause in Form 3CD Disclosure Requirement
Clause 13(e) Adjustments on account of ICDS provisions
Clause 13(f) Effect of various ICDS on profit/loss
Clause 30C Detailed ICDS-wise impact on income
New Clauses Specific disclosures for each ICDS (I to X)

7.3 Sample Disclosure Format

Example Disclosure:

NOTE: SIGNIFICANT ACCOUNTING POLICIES FOR TAX COMPUTATION

1. Basis of Accounting
The company follows mercantile system of accounting. Income and expenses are recognized on accrual basis in accordance with Income Computation and Disclosure Standards (ICDS) notified under Section 145(2) of the Income Tax Act, 1961.

2. Revenue Recognition
Revenue from sale of goods is recognized when significant risks and rewards of ownership are transferred to the buyer, in accordance with ICDS IV.

3. Change in Accounting Policy
During the year, the company changed its method of inventory valuation from Weighted Average to FIFO method. This change was necessitated to comply with ICDS II provisions. The effect of this change has resulted in an increase in taxable income by ₹3,50,000.

8. PRACTICAL EXAMPLES

8.1 Example 1: Prudence vs ICDS I Treatment

Scenario: ABC Ltd. holds shares of XYZ Ltd. as stock-in-trade purchased at ₹100 per share. As on 31st March 2024, the market price is ₹80 per share.

Particulars Cost Price Market Price
100 shares of XYZ Ltd. ₹10,000 ₹8,000
Unrealized Loss ₹2,000

Treatment under AS-1 (with Prudence):

  • Value shares at lower of cost or market value = ₹8,000
  • Recognize unrealized loss of ₹2,000 in P&L
  • Closing stock = ₹8,000

Treatment under ICDS I (without Prudence):

  • Mark-to-market loss NOT recognized (ICDS I para 4(ii))
  • Value shares at cost = ₹10,000
  • No loss recognized in income computation
  • Loss recognized only when shares are actually sold

Tax Implication:

Taxable income is higher by ₹2,000 under ICDS I as compared to AS-1 treatment.

8.2 Example 2: Change in Accounting Policy

Scenario: DEF Ltd. has been using WDV method for depreciation. In FY 2023-24, it proposes to change to SLM method.

Particulars Amount (₹)
Original Cost of Asset 10,00,000
WDV as on 01-Apr-2023 7,00,000
Remaining Life 7 years

Depreciation Calculation:

Method Calculation Depreciation
WDV @ 15% ₹7,00,000 × 15% ₹1,05,000
SLM (New) ₹7,00,000 ÷ 7 years ₹1,00,000
Difference ₹5,000

ICDS I Requirements:

  1. Reasonable Cause: Company must demonstrate reasonable cause for change (e.g., change in legal requirements, better representation of usage pattern)
  2. Disclosure: Must disclose:
    • Nature of change: Change from WDV to SLM
    • Reason: Better reflection of asset usage
    • Impact: Profit increased by ₹5,000
  3. Tax Impact: Taxable income increases by ₹5,000

Note: Without reasonable cause, the change may be rejected by tax authorities.

8.3 Example 3: Substance Over Form

Scenario: GHI Ltd. "sells" machinery to JKL Bank for ₹50,00,000 but retains right to buy back after 3 years at ₹55,00,000. GHI continues to use the machinery.

Legal Form: Sale transaction with separate buyback agreement

Economic Substance:

  • GHI retains all risks and rewards of ownership
  • GHI continues to use the asset
  • Fixed buyback price suggests financing arrangement
  • Difference of ₹5,00,000 represents interest

Treatment under ICDS I (Substance over Form):

Aspect Treatment
Transaction Type Loan/Financing (not sale)
Asset Remains in books of GHI Ltd.
₹50,00,000 received Treated as borrowing (Liability)
₹5,00,000 difference Finance cost spread over 3 years
Depreciation Continues to be charged

Annual Treatment:

Year Interest Expense Depreciation
Year 1 ₹1,66,667 As per policy
Year 2 ₹1,66,667 As per policy
Year 3 ₹1,66,666 As per policy

Key Point: This is a financing transaction, NOT a sale, based on substance over form principle of ICDS I.

8.4 Example 4: Accrual Basis

Scenario: MNO Ltd. (follows mercantile system) has the following transactions in March 2024:

Date Transaction Amount (₹) Payment/Receipt Date
15-Mar-24 Services rendered, Invoice raised 2,00,000 10-Apr-24 (received)
25-Mar-24 Rent for March (Bill in April) 50,000 05-Apr-24 (paid)
31-Mar-24 Interest accrued but not received 15,000 30-Jun-24 (to be received)

Recognition under ICDS I (Accrual Basis):

Transaction Recognition in FY 2023-24 Reason
Service Income ₹2,00,000 Services rendered in March, invoice raised
Rent Expense ₹50,000 Relates to March, even though bill received in April
Interest Income ₹15,000 Accrued in March, right to receive arose

Taxable Income for FY 2023-24:

Particulars Amount (₹)
Service Income 2,00,000
Interest Income 15,000
Total Income 2,15,000
Less: Rent Expense (50,000)
Net Income 1,65,000

Note: Cash receipt/payment dates are irrelevant for income recognition under accrual basis mandated by ICDS I.

9. IMPORTANT CASE LAWS

9.1 Landmark Judgment: Chamber of Tax Consultants Case

The Chamber of Tax Consultants & Anr. vs Union of India & Ors.

Court: Delhi High Court

Citation: W.P.(C) 5595/2017

Date: November 8, 2017

Bench: Justice S. Muralidhar and Justice Pratibha M. Singh

Facts of the Case:
  • Chamber of Tax Consultants filed writ petition challenging constitutional validity of ICDS
  • Challenged Notification No. 87/2016 and 88/2016 dated September 29, 2016
  • Also challenged Circular No. 10/2017 dated March 23, 2017
  • Main contention: ICDS provisions override binding judicial precedents
Arguments by Petitioners:
  • ICDS violates Articles 14, 19(1)(g), 141, 144, and 265 of Constitution
  • Amounts to excessive delegation of legislative powers
  • ICDS overrides Supreme Court and High Court judgments
  • Creates discrimination between cash and mercantile system taxpayers
  • Lacks legal certainty and creates compliance burden
Key Issues Before Court:
  1. Whether Section 145(2) amounts to excessive delegation?
  2. Whether ICDS can override binding judicial precedents?
  3. Whether ICDS provisions violate constitutional provisions?
  4. Validity of specific provisions of various ICDS

9.2 Court's Ruling on ICDS I

Judgment on ICDS I - Accounting Policies

HELD: ICDS I provisions removing "prudence" concept are ULTRA VIRES and STRUCK DOWN

Court's Reasoning:

  • Concept of prudence is integral to mercantile system of accounting
  • Removal of prudence contrary to settled judicial precedents
  • Prudence principle recognized by Supreme Court in multiple cases
  • ICDS cannot override fundamental accounting principles established by courts

Specific Finding:

"ICDS I which does away with the concept of 'prudence' is contrary to the Act and binding judicial precedents and is therefore unsustainable in law."

Important Observations:
Observation Impact
Section 145(2) to be read down Cannot override binding judicial precedents
ICDS not meant to overrule Act/Rules Act provisions prevail over ICDS
Prudence removal unconstitutional ICDS I prudence provisions struck down
Executive cannot validate contrary to law Validation is legislative power only

9.3 Other Relevant Case Laws

1. CIT vs. Triveni Engineering & Industries Ltd.

Citation: (2011) 49 DTR 253 (Del)

Court: Delhi High Court

Principle: Prudence principle recognized - provision for known liabilities is allowable

Relevance: Supports the view that prudence is fundamental to mercantile accounting

2. CIT vs. Advance Construction Co.

Principle: Prudence in accounting for anticipated losses

Relevance: Established that prudence cannot be ignored in tax computation

3. Rotork Controls Pvt. Ltd. vs. CIT

Citation: (2009) 314 ITR 62

Court: Supreme Court

Principle: Provision for present obligations in respect of past events is allowed

Relevance: Supports accrual principle and recognition of liabilities

4. Commissioner of Income Tax vs. Poddar Cement P. Limited

Citation: (1997) 226 ITR 625 (SC)

Court: Supreme Court

Principle: Doctrine of "updating construction" - law must acknowledge emerging trends

Relevance: Need for accounting standards to evolve with business practices

5. Shri Prithvi Cotton Mills Limited vs. Broach Borough Municipality

Citation: (1969) 2 SCC 283

Court: Supreme Court

Principle: Executive cannot override binding judicial decisions

Relevance: Fundamental to Chamber of Tax Consultants judgment

9.4 Post-Judgment Scenario

Current Status (as of 2025):

  • Parts of ICDS I relating to prudence have been struck down
  • Taxpayers can rely on prudence principle as per judicial precedents
  • Where ICDS conflicts with binding judgments, judgments prevail
  • Income Tax Act provisions always prevail over ICDS
  • Assessees should maintain documentation supporting their position

10. QUESTIONS & SOLUTIONS

11. IMPLEMENTATION FLOWCHART

ICDS I Applicability and Compliance Flowchart

START
Assessee has Business/Professional Income
DECISION 1
Is the assessee Individual or HUF?
YES →
DECISION 2
Tax Audit required u/s 44AB?
NO →
ICDS NOT APPLICABLE
Follow regular accounting
YES →
Continue to Decision 3
NO →
(Company, Partnership, etc.)
Continue to Decision 3
DECISION 3
Following Mercantile System?
NO (Cash System) →
ICDS NOT APPLICABLE
Follow cash accounting
YES →
Continue
ICDS APPLICABLE
Must follow ICDS for tax computation
STEP 1: Identify Significant Accounting Policies
• Revenue recognition
• Depreciation method
• Inventory valuation
• Foreign exchange
• Others
STEP 2: Ensure Compliance with Fundamental Principles
✓ Going Concern
✓ Consistency
✓ Accrual Basis
STEP 3: Apply ICDS I Provisions
• Substance over form
• No prudence (unless court precedent)
• No MTM losses (unless specific ICDS)
• Reasonable cause for policy changes
DECISION 4
Any change in accounting policy?
YES →
Document:
• Nature of change
• Reasonable cause
• Quantified impact
• Disclosure
NO →
Continue
STEP 4: Compute Taxable Income
Book Profit (AS/Ind AS)
+ ICDS Adjustments
= Taxable Income
STEP 5: Disclosure in Form 3CD
• Clause 13(e) - ICDS adjustments
• Clause 13(f) - Effect on profit/loss
• Clause 30C - ICDS-wise impact
• Significant accounting policies
DECISION 5
Conflict with judicial precedent?
YES →
Judicial Precedent Prevails
(Per Chamber of Tax Consultants case)
Document position clearly
NO →
Apply ICDS provisions
FILE INCOME TAX RETURN
With ICDS-compliant computation

Key Decision Points Summary

Decision Point Question Action
Decision 1 Individual/HUF? If yes, check tax audit requirement
Decision 2 Tax audit required? If no (for Individual/HUF), ICDS not applicable
Decision 3 Mercantile system? If no (cash system), ICDS not applicable
Decision 4 Policy changed? If yes, document reasonable cause and impact
Decision 5 Conflict with precedent? If yes, judicial precedent prevails

📌 EDUCATIONAL DISCLAIMER: This resource is for educational purposes only and does not constitute legal advice. For specific tax matters, consult a qualified Chartered Accountant or tax professional. Tax laws and interpretations may change. Always verify with current provisions and professional guidance.

© 2025 ICDS Educational Resource | For Academic Use Only

Last Updated: November 2025 | Based on provisions as of January 2025

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