Mandatory Validation of UDIN with Income Tax Forms/Reports

The Income-tax e-filing portal has completed its integration with the Institute of Chartered Accountants of India (ICAI) portal for validation of the Unique Document Identification Number (UDIN) generated from ICAI portal by the Chartered Accountants for documents certified/attested by them and factored mandatory quoting of UDIN with effect from 27th April 2020 for documents certified/attested in compliance with the Income-tax Act, 1961 by a Chartered Accountant. Through this process, UDIN provided for the audit reports/certificates submitted by the Chartered Accountants in the e-filing portal are being validated online with the ICAI. The Institute of Chartered Accountants of India, in its gazette notification dated 2nd August 2019, had made a generation of UDIN from ICAI website mandatory for every kind of certificate/tax audit report and other attests made by their members as required by various regulators. The objective of the said monitoring is to curb fake certifications by non-CAs misrepresenting themselves as Chartered Accountants.

Extension Of One Time Measure To Update UDIN

CBDT has given the second extension for updating UDINs on all forms and can be done latest by 15th February 2021 for treating these forms as valid and a member is required to validate the same to avoid invalidation. Earlier, CBDT has given a one-time relaxation for forms latest by 31st December 2020 for treating these forms as valid. However, on the persuasion of The Institute of Chartered Accountants of India, the date has now been extended to 15th February 2020 for the Forms uploaded from 26th April to 26th November. From 26th November onward, the period of 15 days for updating is there. There is no relaxation to that.

CBDT has started validating UDIN while uploading of Tax Audit and other Income Tax Reports and failing to do so, the forms will become null and void. CBDT has come out with this functionality of mentioning UDIN in IT Forms at e-filing portal from 27th April 2020 onwards. It was observed that UDINs for certain IT Forms which have been uploaded on e-filing Portal by the Members during 27th April 2020 to 26th Nov. 2020 has not yet been updated resulting invalidation of these forms.

The Present 15 Days Time To Upload UDIN

The present procedure to the form number selected at the UDIN Portal while generating UDIN, same form number has to be selected at e-filing Portal also while updating UDIN at the time of uploading Reports or if a UDIN for the form has not been generated at that time and the CA desires to upload the same without UDIN that can be done. However, within 15 calendar days of uploading, UDIN generated for the form should be updated to avoid the form uploaded being treated as invalid. The relevant Form Number is selected from the various Online Forms of IT Tax which appear in the Drop-down under Document Category of GST and Tax Audit. The said forms are Form 6B , Form 3AC, Form 3AD ,Form 3AE , Form 3CA , Form 3CB , Form 3 CE , Form 3 CEA ,Form 3CEB ,Form 3CEJ , Form 3CEJA,Form 3CLA , Form 10B,Form 10BB, Form 10 CCB, Form 10 CCBBA, Form 10 CCBC, Form 10 CCBD, Form 10 CCC, Form 10 CCF, Form 10 DA, Form 15 CB, Form 26, Form 27, Form 29 B ,Form 29 C, Form 49 C ,Form 56 F, Form 62, Form 64, Form 64A ,Form 64D ,Form 64E ,Form 66 . UDIN is being validated by e-filing portal online with UDIN Portal of ICAI on three parameters of Membership No of Member (MRN), UDIN and Income Tax Form Number.

How To Validate The Earlier Uploaded Forms

The forms filed on the e-filing portal of the Income Tax department between 27th April 2020 and 26th November 2020 is requiring to be revisited and to validate. However as the utility was commissioned by the Department on 26th April, the forms were being validated. However, If UDIN status indicates, ‘update UDIN’ though a form has been uploaded with valid UDIN. That means the Taxpayer has not accepted the uploaded form. In case an error has been identified after the upload of the form, please ensure that the taxpayer does not accept the form that has been uploaded. Upload the corrected form with the same UDIN and ensure that the taxpayer accepts the corrected form. In that case, the CA would be able to modify the UDIN till the acceptance by the taxpayer. However, If the mistake or error in the form of attachment has been noticed subsequent to taxpayer accepting the form linked to a valid UDIN, then the process is only revising the form with new UDIN generated by revoking the earlier generated UDIN of the submitted form.

A link ‘View/Update UDIN details’ is available under My Account tab. User must click the link and shall be redirected to ‘View/Update UDIN details’ and there are two terms attached to it. i.e. the Consumed and the Unconsumed.

The status ‘Consumed’ under ‘UDIN status’ indicates that the form uploaded by the CA with a UDIN has been accepted by the taxpayer and the UDIN linked to the form cannot be used for upload of another form or the revision or correction of the form already uploaded without its revocation. The status ‘Unconsumed’ under ‘UDIN status indicates that the form uploaded by the CA with a UDIN has been rejected by the taxpayer and the form can be re-uploaded using the same UDIN

Consequences Of Not Validating The UDIN

In case, a member uploads without UDIN or fails to update the UDIN within 15 calendar days, but the form uploaded has been accepted by the the taxpayer then the form uploaded will be treated as invalid with all due consequences of law attracted. Further, in case of the form uploaded by the CA with UDIN but not accepted by the taxpayer, the form uploaded will not be considered as a valid submission by the taxpayer till it is accepted by the taxpayer. The date of submission of the form by the taxpayer will be the date on which the taxpayer accepts the form uploaded by the CA or the date on which the CA has furnished the UDIN, whichever event takes place later as the case may be. In case UDIN of a form is revoked after its acceptance by the taxpayer, then the form submitted with that UDIN will be treated as invalid on the date on which the UDIN is revoked with due consequences of law attracted. In case UDIN of a form is revoked after its acceptance by the taxpayer, and a revised form with fresh UDIN is uploaded, then the date on which the taxpayer accepts the revised uploaded form will be considered as the date of submission.