Karnataka State Chartered Accountants Association ®

Date: 27th April 2022

To,
Smt. Nirmala Sitharaman
Hon. Union Minister of Finance and Corporate Affairs
Government of India

Hon’ble Madam,

SUBJECT: DIFFICULTIES IN THE USE OF MCA21 VERSION 3.0

The Karnataka State Chartered Accountants Association (R) (in short ‘KSCAA’) is an association of Chartered Accountants, registered under the Karnataka Societies Registration Act, in the year 1957. KSCAA is primarily formed for the welfare of Chartered Accountants and represents before various regulatory authorities to resolve the professional problems faced by chartered accountants and the business community.

At the outset, we congratulate and applaud the sincere efforts of your ministry and MCA in launching Version 3.0 of the MCA21 portal starting with the LLP module. As India is celebrating Azadi ka Amrit Mahotsav and has entered into Amrit Kaal, the 25-year-long leadup to [email protected], this platform is envisaged to greatly leverage analytics, artificial intelligence and machine learning and thereby bring further ease in the statutory compliances and filings under the Limited Liability Partnership Act.

In the past, we have written to your good selves, populating various issues, challenges, and hardships being faced by stakeholders & professionals, and suggesting possible solutions to the same. Herein, we are presenting before your good selves for your kind consideration certain issues that are being faced while interfacing with the revamped portal by various stakeholders including professionals like Chartered Accountants. Please note that this is not an exhaustive list, but only an illustrative one.

I. Process Inconsistency between LLP Incorporation & Company Incorporation

1. While incorporating LLP in the new portal, there is no continuity in the application since we are expected to file a fresh FiLLiP application, even after RUN-LLP is approved.

In contrast, while incorporating companies, the application continues in Spice+ Part B, once the RUN request is approved.

2. Stakeholders are not given an option to “save draft”. As a consequence of this, the user is required to re-fill the entire form repeatedly in case of session time-outs due to any technical or any other reason including network issues.

3. Once the FiLLiP form is submitted, PDF versions are generated for affixing DSCs and submitting the final application. However, there is no option to edit the PDF once they are generated. This, coupled with the above problem of not being able to save drafts, leads to an unwarranted wastage of time and efforts of users.

It is our sincere request and suggestion to you to kindly look into these issues and accordingly fix these issues as mentioned above by aligning the functionalities of the LLP web portal with the existing Company’s web portal.

II. Invalid Errors

1. In certain cases, such as during the Filing of Form-3 and Form-4, we have seen an error popping up as ‘attachment error and DSC error’, even when the attachments are proper / DSC is properly affixed.

2. There seems to be a data validation error concerning the date column in Form 8.

3. In certain cases, the portal pops up “Invalid LLPIN / DIN / DPIN” error even if the LLPIN / DIN / DPIN entered has been cross-verified with the Master Data and found to be valid.

4. On the “My Application” page, when clicked on Historical Forms, the screen goes blank and becomes unresponsive.

5. The SRNs generated on the new portal are not trackable. When we click on the ‘Track SRN status’, we are redirected to the old portal and the “Invalid SRN” error is thrown up!

Difficulties in the Use of MCA21 Version 3.0

We request you kindly look into the above errors and fix them appropriately. Further, in case the applicant/user commits any mistake or errs while filling the forms, the portal should ideally display appropriate errors with meaningful information indicative of the resolution.

We are presenting before your good selves the above-enumerated issues which are more of a technical nature that are being currently faced by the users representing trade, industry and professionals All these issues may be referred to as “starting troubles” or “initial teething trouble” in the implementation of Version 3.0 of the MCA 21 portal. However, these issues must be fixed as soon as possible to ensure implementation of the new portal is successful and fetches the avowed objectives of the Government. Wherever relevant against the issues that are highlighted above, we have also given our recommendations for your kind consideration. We herewith earnestly request your good selves to kindly initiate appropriate action to fix all the issues highlighted above in the newly launched Version 3.0 of the MCA21 portal and help improve the user experience and ease in compliance.

Further, we request your good selves to take the necessary steps to waive additional fees, relax penal provisions and extend the due dates wherever required, until the portal stabilizes.

We the members of the Karnataka State Chartered Accountants Association, on behalf of the entire Chartered Accountants community and also on behalf of the trade and industry in the state of Karnataka appeal to your good selves to kindly consider our above recommendations on various issues populated as above.

Yours sincerely,

For Karnataka State Chartered Accountants Association ®
CA. Chandan Kumar Hegde CA. Sujatha Raghuraman CA. Ganesh V Shandage
President Secretary Chairman

Representation Committee

Cc to:

1. Shri Rao Inderjit Singh, Union Minister of State in the MCA

2. Shri Rajesh Verma, Secretary, MCA

3. Shri Manmohan Juneja, Director General of Corporate Affairs

4. Shri C.V. Sajeevan, ROC Bangalore

Also Read:

FAQs on Form 11 LLP & FiLLiP form

MCA issues updated FAQs on V3 Portal

LLP V3 Portal causing lot of problems for stakeholders

MCA issues V3 Login FAQs

Request to simplify form filing process on new MCA/LLP portal

How to Register/Associate DSC of Director/Partner on MCA V3 Portal

How to login in MCA V3 module of LLP

MCA 21 Version 3- LLP Filing – Issues/ Feedback (If any)

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