While reporting in Para 3(a) of Form No. 3CB, the tax auditor should report observations/comments/discrepancies/inconsistencies that are of a qualificatory nature which affect his reporting about obtaining all the information and explanations that were necessary for the purposes of the audit, about the keeping of proper books of account by the head office and branches of the assessee and about the true and fair view of the financial statements. Further, only such observations/comments/discrepancies/inconsistencies that are of a qualificatory nature should be mentioned in Para 3(a).
Para 5 of Form No. 3CB requires the auditor to report whether, in his opinion and to the best of his information and according to the explanations given to him, the particulars given in Form No. 3CD are true and correct subject to observations/qualifications, if any. The auditor may have a difference of opinion about the particulars furnished by the assessee, and he has to bring these differences under various Clauses in Form No. 3CD. Further, the Tax Auditor in Para 5 of Form 3CB should give his observations/comments/adverse remarks/disclaimers found during their audit on any of the clauses of Form 3CD, wherever required.
Hence, Para 3(a) in Form 3CB pertains to qualification about the true and fair view of the financial statements. In contrast, Para 5 specifically concerns the qualifications on true and correct reporting in any of the Clauses of Form 3CD.