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STRATEGY FOR BUDGET COLLECTION

The following could be the strategy for achieving the budget target for Financial Year 2009-2010:

(A) Improving Advance Tax Collection

In 2008-09 the share of collection from advance tax in real terms and also actual collection of advance tax has shown a declining trend vis-à-vis previous year. During 2008-09. the Department has collected around Rs.1,63,100 crore (provisionally) which is around 6.2% less than what it had collected during 2007-08. It is primarily because of shortfall in advance tax collections, the Income Tax Department could not achieve the Budget Targets for 2008-09. Therefore monitoring of the advance tax should be done in right earnest starting from the beginning of the year The following broad guidelines for increasing advance tax collections are to be followed by the field authorities:-

  • In the Finance Bill, 2009, the subsection (1) of section 115JB has been amended to increase the MAT rate to fifteen percent from the existing ten percent. Field formation should closely monitor the increase in Advance Tax because of increase in the MAT rate.
  • The Chief Commissioners and Commissioners to personally monitor advance tax payments by top 100 taxpayers.
  • The Quarterly Financial Statements of the large and medium corporations to be examined and co-related with the advance tax paid by them for the quarter,
  • Cases in which large amounts were paid by the Taxpayers as Self Assessment Tax should be taken from OLTAS and they should be persuaded to pay the same as Advance Tax. If needed, recourse to issue of notice U/s 210 the I.T. Act, 1961 may be taken.
  • Cases where substantial additions were made and confirmed in appeals should be identified and the assesses should be persuaded to pay the additional tax burden on similar issue as Advance Tax, If needed, recourse to issue of notice U/s. 210 of the Income Tax Act 1961 may be taken.
  • Industry wise sectoral analysis of the growth trend should be made from various sources to arrive at a bench-mark, and individual cases showing large variation should be monitored. If need be, suitable action U/s.  133A may be under taken to ensure correct advance tax payment.
  • The stop filers and non-filers should be identified, preferably after cross verification from AIR, STT or TD S data and steps should be taken to bring these prospective assesses under advance tax net.
  • Surveys under section 133A should be carried out in selective cases to increase advance tax collections.
  • Monitoring of advance tax payment on account of Minimum Alternate Tax (MAT) in cases to which sections 10A and 10B apply should continue as in last year. The assessee’s should be properly educated in such cases.
  • Frequent interactions by CCsIT/CsIT with the industry/trade associations and professional bodies with a view to explaining the tax-policies of the Government and receiving feed backs on the financial condition of various industries/trades should be continued.
  • Payment of advance tax by taxable local authorities and educational institutions should be monitored.
  • The COT/ CIT shall identify such companies in their charge, which are liable for tax on distributed dividend as per the provisions of section 1150 and monitor its timely payment for the current year Similarly, installments of FBT should be closely monitored.

Apart from the above general guidelines, the Chief Commissioners may devise their own strategy in view of the local factors. The feedback on the steps taken by the Chief Commissioners and the resultant gains would be taken by the Zonal Members of CBDT periodically through reports or while on a visit to the stations.

(B) Collection from Regular Assessment

The regular assessment tax (RAT) is one of best tools available to the Department to collect taxes. The collection from RAT not only showcases the effort of the Department to collect taxes but can also have a great deterrent effect on the tax evaders. During 2009-10, the Department has collected around Rs 31,242 crone from RAT which is around 8,74% more than the corresponding figure last year. The share of collection from RAT (as a percentage of total collection) has gone up from 921% in 2007-08 to 924% in 2008-09. However there is a great potential in augmenting collection from RAT.

1. Some of the issues involving substantial revenue implication which can be targeted during the scrutiny proceedings are as follows;

(i) AS (Accounting Standards) 11, in its original form, required companies to report their foreign currency monetary items based on the closing exchange rate at the end of an accounting period, The gain/loss arising from the exchange difference had to be recognized in the profit and loss account. With corporate India carrying significant foreign currency loans, companies suffered mark-to-market (MTM) losses on such restatement especially over the past year, when  the  rupee  s aw  sign ificant  depreciation, expanding the  loan value in rupee terms. Although notional, this resulted in depressed earnings. To grant some temporary relief to companies, the Government amended AS 11 on 31st March’09, providing an option to capitalize/amortize the exchange differences on long-term foreign currency monetary items (typically overseas borrowings). This provision, effective with retrospective effect from December 2006, would be available up to Financial Year 2010-11. Following this amendment, companies with forex loans can now adjust the loss or gain arising from currency fluctuation by adding to or deducting from the cost of fixed asset, if such borrowing were incurred for acquiring the asset. The treatment, in essence, would help bypass the P&L account and make adjustments directly in the balance sheet, thus providing immediate relief to earnings.

The above amendment to AS-11 has substantial revenue implications on earning of companies since the option once exercised is irrevocable. The company has discretion not to adopt the treatment as per the notification and can follow the principles stated in AS 11. All these issues may be examined by the AUs threadbare during the scrutiny proceedings.

(ii) In the Finance Bill, 2009, a clarificatory amendment in Section 147 has been made with retrospective effect in which it has been clarified that the AO can assess or reassess income in respect of any issue which comes to. his notice subsequently in the course of proceedings under the 147 section, notwithstanding that the reason for such issue has not been included in the reasons recorded under sub-section (2) of section 148,

This may have substantial impact on reassessment of income under section 147 of IT Act, 1961.

{iii) The definition of charitable purpose has been amended vide Finance Bill.. 2008. Hence some of the income of trusts will be taxable w.e.f, 1st April’09. Therefore the tax -exempt status of most of the trusts and other such charitable organizations may be closely scrutinized, if the case is picked up in scrutiny, during assessment proceedings. Activities of Sports Bodies which are engaged in commercial activities and Private Educational Institutes etc should be closely monitored in the light of amendment to provision of section 2(15) of Income Tax Act’61,

(iv)       Cases of diversion of turnover from taxable units to units covered under section 10A, /OS, 80IA & 80IB

(v)      Cases where qualifying conditions for availing deductions under these sections are not fulfilled, e,g. contractors of infrastructure projects claiming deduction uis 80 IA(4) even though it was meant for assesses who “maintain and operate’ infrastructure projects; or deductions claimed by assessees as 551 even when the company became large scale unit etc:

(vi)  Cases where depreciation has been claimed without arriving at the actual cost of assets as per Sec 4-3(1) especially at the time of corporatization, amalgamation, demergers etc.;

(vii) Cases where arms length price was determined without applying correct variables;

(viii Cases were house property income shown as business income;

(ix)     Cases of private limited companies where unaccounted income introduced in the companies in the form of share premium;

(x)      Cases of builders where the income has to be taxed on year-to-year basis but are shown on project completion basis etc.

(xi) Further, tools of investigation like analysis of trading results and ratio analysis of various sectors and gathering of information in cases of assessees dealing in shares and commodities from stock exchanges, NSE, BSE, MCX and NCDEX or there registered brokers may be frequently resorted to. Obviously these examples are only demonstrative and not exhaustive. Each CCIT/ CIT will have to identify issues relevant to his jurisdiction and circulate the same to his assessing officers to Improve the quality of assessment and to prevent loss of revenue;

2. Surveys should be used as a tool for augmenting tax collections more frequently & effectively. The cases for conducting surveys should be selected with due diligence and these should be conducted professionally.

3. Study of data has revealed that the department collected 25% more revenue in cases referred to valuation cell, The officers are advised to refer high value cases to the valuation cell for estimating cost of investment uis 142A and fair market value Ws 55A,

4. As indicated last year, the number of liaison officers maintained by foreign companies in India continues to be a cause of concern. Some of these liaison officers are carrying out business in India even while claiming themselves to be liaison officers, This aspect needs to be taken into account while evolving strategy for tax collection. Further, w.e.f. 1.4.2003 the definition of Local Authorities has been changed in Section 10(20) of the Income-tax Act. Assessing officers have to take action to take up these cases for scrutiny and determine correct tax in these cases.

5. As already stated, the purpose of a good addition is to collect additional revenue. In order to ensure collection of tax in good cases, it is imperative that the Assessing Officers also identify at the time of assessment, movable and immovable assets of the assesses that can be used for collection of tax. If required, action as 281 B should also be taken to safeguard the interest of Revenue.

6. It is noticed that disposal of scrutiny assessment slows down after December. Apart from Large demand cases, current scrutiny cases requiring external enquiry and investigation should be taken up in right earnest and disposed off during the year as far as possible.

7. It is the duty of the administrative Commissioners to ensure that proper assessments are made. For this purpose the CsIT should carry out review of the assessments and give specific findings whether it is a case of under assessment, proper assessment or over assessment. The CsIT should take remedial action immediately. CCIT should review the work of CsIT in this area. It will be the duty of each Member of the CBDT to monitor this work of GCsfT/CsIT during their visits.

8. Orders for remedial action in the cases where major audit objection has been accepted by the Department should be expeditiously passed and appropriate recovery be made within the year itself.

9. The policy in respect of issue of refunds of large amount shall continue to be that all large refunds (Rs.1 crore and above in the case of Delhi, Mumbai, Chennai, Kolkata, Bangalore, Hyderabad, Ahmadabad and Pune and Rs. 25 lakh and above for other stations) shall be issued by the assessing officers after obtaining prior administrative approval of the Commissioner of Income Tax concerned. Before according approval to issuance of refund in a case, the Commissioner of Income Tax would satisfy himself that there are no high demand scrutiny assessments in that case that can be quickly completed and the refund appropriated towards the demand so raised.

(C)  Enhancing Collection by way of TDS:

The collection from TDS/TCS during 2008-09 records a figure of around As 1,33,000 crore (provisional), which is around 26% more than the corresponding collection previous year. The share of collection from TDS/TS has also gone up from 33.7% in 2007-08 to 39.3% in 2008-09. Through the non-intrusive mechanism of TDS, the income Tax department can augment its revenue by leaps & bounds and also tap classes of person’s hitherto escaping tax net, There are several new economic activities that can be brought under the coverage of TDS. There is need for strengthening TDS administration to ensure that TDS is properly deducted and deposited. Since the growth in TDS/TCS is crucial to achieving the Budget Target, no posts of TDS may be kept vacant. A number of measures are suggested below to augment the collection from TDS/TCS:-

1) More  surveys/inspections

More direct action is needed to ensure that:?

a)        Effective survey should be done which have wider and countrywide ramification which may result into better compliance of TDS provisions.

b)             TDS is deducted in all liable cases.                    •

c)           Deduction is made at the proper rate

d)          Deducted amount is promptly deposited in Government account. Similar action is required in respect of TCS as well

2) Organizing Workshops/ seminars/ meetings

More number of workshops, seminars and meetings with the Trade industry, association, deductors and tax practioners etc., needs to be organized for educating them so that there is better compliance with the provisions of TDS & TCS,

3) Publicity campaign against TDS defaulters

Visual and print media should be used for mounting •campaign against TDS/TCS defaulters. Vide publicity should be given in the media about the penal measures regarding TDS/TCS defaults. More stress on identification of non filers of TDS returns and taking follow-up action.

4) Educating DDOs

Educating The DDOs of large organizations and Govt. sector deductors will ensure better compliance of MIS provisions. This practice has been carried on in the last two years and the same should continue even more vigorously.

5) Issues having all-India ramifications should be closely monitored

During the course of surveys/inspections if a new modus operandi to avoid deduction of tax is detected this may have implications in •other cases on an all-India basis. These issues should be immediately brought to the notice of other CIT(TDS) charges and the compliance in this regard should be closely monitored, Some of these are briefly discussed as under:-

a)     Land acquisition far creation of SE Z, industrial Parks and Infrastructure Developments can be brought under 194LA. However interest paid on delayed compensation received may be subjected to TDS under 194A,

b)          Payments made to hospitals through Third Party Administrators (TPAs) it was noticed that the TPAs are not deducting taxes at source while making payments to the hospital even though prima facie it appears that provisions of Section 194-J are applicable,

c)           Wheeling charges paid by Electricity Distribution Companies to companies owning transmission line. However, TD S is not being deducted as per the provisions of Section 194J.

d)     TCS on Royalty received for mining contracts. Defaults have been detected in some of the cases and potential revenue leakage of substantial amount has been plugged.

6) Deferment of TD S payment to be discouraged

Recently there was some TV news that many of the assessees are deferring the TD S payments into Government account because under the existing rate of interest, deferment of deposit of tax deducted at source is a cheaper source of fund as compared to fresh loan from the market. Loss making companies need to be checked as they have the tendency to default

7) Quick decision of appeal cases having substantial revenue potential

Many good orders U/s. 201(1) and 201(1A), having substantial revenue potential are locked up in appeal. Full recovery in such cases is practically not enforceable. There are also instances where similar issues are involved in other cases but the PLO’s are not passing the order till the issue is decided by CIT(Appeal). In such cases there is a need to request the concerned CIT(Appeal) to decide the matter expeditiously.

8) Utilization Of system generated information

Recently DIT(Systems) had distributed a list where there is a delay in payment of TD S, quantifying the possible interest payable u/s 201(1A).

In Mumbai a list was generated by the system, from the database of e-filed returns, where disallowance u/s 40(a)(ia) could be made.

These types of reports and their analysis would be very handy for detecting the defaults and raising fresh demands and enforcing collections.

9) Prompt disposal of proceedings u/s 201(1) & 201(1A)

Proceedings u/is 201(1) & 201(1A) should be quickly disposed so that demand is raised and collection is made.

10) Increased use of ICE

Increased use of ICE (information, Communication & Education), so that there is greater understanding of TD S and TS provisions by the tax collectors and deductors.

11)  Checking avoidance of IDS/ TCS liability in respect of the following payment,/ transactions;                                                                                                                 •

Checking avoidance of TDS/ TCS liability in respect of the following payment,/ transactions; 

1. Payment for purchase of land under sale deed by project implementing authorities towards compulsory land acquisition for SEZs/public utilities implemented under Fast Track procedure where the implementation is not done directly by state government.

2. Payment of commission by cooperative banks to agents/daily deposit collectors

3. Annual Maintenance Charges paid by the big Corporate/Banks Govt. Offices etc to the service providers for maintenance of computer systems which include hardware as well as software maintenance. TD S is to be generally made on such payments

4. Payments made by companies operating Star Hotels to the owners of buildings in which such hotels are run

5. Payments made for hiring of vehicles, hiring of aircrafts, helicopters on time charter basis on which tax is generally deducted Las 1940 as against 1941 claiming it as contract for carriage of passengers.

6. Payments made for hiring of tugs/launches by the port operation for guiding ships for anchorage on which tax is generally deducted u/s 1940 as against 1941.

7. Demurrage paid on goods to be loaded on the ship or unloaded there from which is not penalty but is in the nature of payment for warehousing charges and, hence, tax is to be deducted on the same u/s 1941.

8. TCS on sale of timber in High Sea,

9. Salary payments to doctors u/s 192 camouflaged as payment for professional services u/s 194J in corporate hospitals.

10. Payment of lease rentals in respect of transmission towers used by cellular phone operators.

11. TCS on sale of timber by traders where the purpose is further trade and not end use.

12. Payment of interest in respect of loansifunds taken from NSFCs and sister concern/companies by firms and companies.

13. Payment of hire charges in transport/travel agency business.

14. Payments made on acquiring satellite rights/TV rights on films u/s 194 J.

15. Payment made towards hiring a plan/machinery/equipment u/s 194 I.

16. Payments towards hiring of windows of showroom for displaying their products uis 194 I.

17. Payments of interest earned by builders on advance amount taken by them from the buyers of flat. which subsequently is adjusted against the sale consideration. (uis 194 A).

18. Payments of commission by the trading merchants to the credit card companies (such as MASTERNISA).

19. Payment by shopkeeper to mall owners camouflaged as profit sharing between them to avoid TD S u/s 194 I.

20. Payment of rent by big business houses/airlines on the booking of hotel room for long duration.

21. Payment made to authors, printing press, artists, models etc by book/ magazines publishers.

22. Payments such as hiring of earth moving machinery like cranes, storing machines. dumpers, tracks etc.

23. Payments made for hiring out of tine equipment (sound, light etc) studios and allied services by film producers f tele serial makers.

24. Payments made for hiring out of towing vehicles on wrong parking by traffic police.

25. Payments made in huge amounts by municipal corporations for carrying out various contract work by them.

26. Payments made by big sari houses/garment house/jewelers to models who display their products at fabulous considerations as also to professional photographers dress designers, artists etc,

27. Payments made by public libraries/universities, colleges, museums archives and such institutions to pest control companies for such treatment.

28. Payments made by big business housesirnall owners to security service agency.

29. Payments made by big builders to township planners, hand scrapers, architects and technical consultants etc.

30. Payments made to players, coaches, managers, fitness experts etc. by sport bodies,

31. Payments made on hiring out of vehicle platform for mounting big hoardings, cutouts, hire scenes for advertising of the products services by big companies, such vehicles are parked at some conspicuous place at roadside.

32. Payments made by large business house to land scrapers, gardening contractors on development and maintenance of green sites / road dividers for putting up their company’s advertisement material.

33. Payments made to studio owners for shooting purposes including use of floorsilocations, equipment, settings etc,

34. Payments made to Jr. Artists Association for providing junior artists.

35. Payments made towards film processing, graphic designs, special effects etc.,

36. Distribution rights taken by top artists in lieu of remuneration, which amounts to ‘royalty’ (exploitation of exhibition rights).

37. Commission payments retained by the distributor’s as a pan of the producer-distributor agreement in the nature of constructive payments).

38. Payments made to referral doctors for referring their patients to the corporate hospitals (commission u/s. 194H).

39. Payments made to outside labs for specialized diagnostic services such as D.N.A. printing, immunological assay,

40. Constructive payments Reimbursement of expenses.

41. Franchisee Payments & Non – compete fee & fees for exclusivity rights:

42. Payment on landing and parking charges rent for space used for cargo handling, work of cargo handling, navigation charges and other similar charges to the airport authorities by the airlines.

43. Payment of Royalty to Author, Artists, Musicians etc.

44. Payment of hire charges for machinery and equipments, especially in the construction sector.

45. Payments in the nature of lucky dip, festival bonanza where the prizes are distributed by way of lottery among the eligible customers.

46. Transfer of funds between group companies / firms is taking place and these payments fall within the purview of section 2 (22)(e) (deemed dividend). Tax needs to be deducted at source u/s 194, as this dividend is not covered under the provisions of dividend distribution tax .

47. Payments made by clubs for construction of buildings f swimming pools and maintenance of the same,

48. Payments of lease rentals / hire charges for machinery 1 equipments, especially between sister concerns of group companies,

49. Payment by Multi – National companies and National companies on the lease rentals paid for their retail outlets (194 I).

50. Payments made by State Government Departments for computer training and pre-examination training conducted by them for its personnel and for the public.

51. Payment of compensation and additional compensation on acquisition of land, but tax not deducted U.S.’ 194LA.

52. Payment of interest by Electricity companies on the deposits made by subscribers.

53. It is noticed in the case of some public sector banks that while the TDS is deducted from interest on fixed deposits annually, the interest is being calculated Monthly / Quarterly. and transferred to interest payable. It should be seen that the TD S is accounted on the basis of interest calculation.

54. Payments of rent by splitting the läase agreement into two or more agreements for lease of. the building, lease of the furniture and fixture, agreement for maintenance, etc.

55. Payment of port/ inter-connectivity charges by mobile-telephone service providers to other telephone companies.

56. Payment of interest on belated payment of compensation under Motor Vehicles Act,

57. Accrued interest on term deposits/ cumulative deposits not maturing during the year.

58. Commission paid by cellular companies to sellers of starter packs and recharge coupons for cell phones.

59. Commission paid by airline companies to travel agents.

60. Payment of salaries camouflaged as payments under professional contracts.

61. Payment by banks for taking professional services for recovery of bad debts, loan-processing, credit- verification, etc.

62. Contracts given by Municipal Bodies for installation of streetlights, etc.

63. Payment of Airing Charges to TV channels for broadcast of programmes,

64. Perquisites on account of concessional loans given by companies, especially PSUs, to their employees.

65. TCS under section 2060 on sale of liquor to excise contractors TCS on the sale of liquor by wholesalers to the retailers.

66. Payment of Usance Interest in the ship-breaking business.

67. Payment of interest on term deposits maintained by banks as margin money/ collateral for issue of bank guarantees, NOCs, etc.

68. Payment of charges for Internet Services, VAT Charges, Bandwidth Charges, etc.

69. Payment of fees by hospitals and medical institutes to consultant doctors.

70. Payment of Upfront Commission to banks/ financial institutions for availing financial assistance.

71. Distribution of service charges collected by hotels from the customers amongst the employees.

72.  TDS compliance by multi-national companies in respect of salary and allowances paid to expatiate employees,

73. TDS compliance by entities whose income is exempt from tax.

74. TDS compliance by Municipal Corporations and State Public Works Departments (P.W.D.?),

75. TDS compliance by large Government Departments like Indian Armed Forces, Indian Railways, Department of Posts, etc in respect of TDS on payment for various contracts for works and for professiOnal or technical services given out by them.

76. TDS on contracts lease or license for parking lot and toll plaza and to sale of scrap. Large sellers of scrap like railways, steel plants, iron foundries, ship-breaking units, etc to be identified and the compliance of TCS on sale of scrap need to be verified.

77. Common issues relating to companies having branches in various parts of the country to be taken up at the head office level so that directions are issued by the head office to all the branches for proper TDS compliance. Some illustrative common issues in respect of certain large companies are?

78. TDS on value of perquisite on account of rent-free accommodation by SBI group of banks, BSNL and LIG as determined under rule 3(1) and not as per “‘Standard Rent’.

79. TDS matters relating to companies outsourcing large part of their operations.

80. Payment of post-sale incentives by companies to dealers/ distributors.

81. Payment of interest by Chit Fund companies to their members/ subscribers.

82. Contracts between cinema theatres or multiplexes and the film distributors for supply of prints of movies on collections-sharing basis.

The above areas are only indicative and the Chief Commissioners may identify other areas of TDS avoidance in their. region arising out of local conditions and take suitable action to ensure compliance of TDS provisions.

Do Read-

Criteria / Guidelines for Income tax Scrutiny for Assessment year 2010-11 / Financial Year 2009-2010

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0 Comments

  1. ND says:

    Let me only add that OLTAS kas killed the retired/seior citizens, salaried class people and the small tax payers. In Delhi Salary Circle, no Returns, Rectification applications, letters etc are accepted by the ITO staff unless payment in cash is made by the tax payer for accepting the document in Receipt Counter-or, even if they do, they will not out any seal and stamp, unless bribe is paid. They force hapless retired old men and women to come through SPECIFIC CAS (whose names are suggested by the Staff or the officers). OLTAS and NSDL have jointly created a menace-an honest chairman of CBDT is totally helpless due to union pressures of staff and officers (with the support of Communists), corruption in the department and lack of political and bureaucratic support. The menace is real and all-pervading.

  2. DRPARASJAIN says:

    Humans only ERR . Computers make MESS ( in particular)the departmental computers- when it comes of giving credit . Result is huge demand . I wonder if any one has secured any rectifiction WITHOUT MANUAL FOLLOWb UP . assesseee is responsible for very thing , not the department. I have seen instances where TDS on slary was not reckoned resulting in huge demands. Will there be some accountability??

  3. TDS says:

    Mr. Bidup is more than correct. But the reasons are not only corruption and existence of a very large number of corrupt officers and staff. But a very important reason is that the super bosses do not exercise any supervision throughout the year until March on the way the department functions, with the sole purpose of looting, and suddenly declares war on tax payers resulting actually in the harassment of the salaried classes, small-medium traders/bisinesses, pensioners, etc. so that the suffering is entirely of these people. And. even in this process, all persons from top to bottom only make money. Nothing can be done to stop all this. And, in any case, the govt. has legally allowed the IT people to make money by amending the Act and expanding the scope of scrutiny assessments. And, in 99% of the cases of salaried persons, retired/senior citizens, etc., deliberately overpitched assessments are made raising fake demand totally ignoring TDS cerificates which are either destroyed/removed or mutilated by altering/overwriting PAN nos, as stated by Mr. Bidup.

    We expected the present FM to address himself to the rot in the IT department and promise total transparency in transfer-posting business in this deptt. But he is helpless due to political (and other) compulsions.
    Sufferings of tax payers, forcible extortion of bribes, destruction of TDS cerificates from records, mutiliation with PAN and ignoring TDS, etc will always continue-and refunds will continue to be pending. o one should expect any relief from Ombudsman or any body.

  4. BIDUP says:

    All this translates into:
    indiscriminate harassment of small tax payers
    1)through surveys,
    2)through mindlessly and illegally attaching bank a/cs, never bothering to verify if the notices of demand usually raised ex parte were really served and when,
    3)open demands of huge bribes made by officials/officers at all levels for giving credit for TDS/adjustments of taxes paid, never reflected in the faulty database of the NSDL, and tearing off of the letters written by tax payers to authorities,
    4)illegally collecting wrongly raised demands by altering the PAN written in Pen by tax payers in Returns (say, as is being widely done in Delhi, by making “P” into “R” or “B” into “P” or “R” or making “R” into “P/B”, “I” into “K”, and like with the knowledge/support of the top bosses), so that they are compelled to run to the ITO,
    5)ignoring of petitions by OMBUDSMEN all over the country, especially in Delhi, Hyderabad, Mumbai, etc., and,
    6)as is the established practice for decades, by “requesting” big corporates to deposit huge ad hoc amounts in March on the promise of refunding the same in April and, most important, by refusing to issue any refunds from December to March-which means “NEVER”.
    6)

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