Chartered Accountants Association, Ahmedabad has made a representation to CBDT Chairman on 23.09.2017 with respect to changes in the log In requirements prescribed by an Advisory issued by CBDT on 22nd September on its e-filing website by which CBDT asked  taxpayers to furnish their latest information such as personal and secondary email and mobile phone numbers, address and bank account details. While furnishing such details taxpayer need to ensure that Same email and Mobile number are not used by more than 3 PANS.  Such Restriction is causing lots of hardship to taxpayers and representation on such issues and suggestion for that is as follows :-

Chartered Accountants Association, Ahmedabad

23rd September, 2017

The Chairman,
Central Board of Direct Taxes,
Ministry of Finance.
Government of India,
New Delhi

Re: issues and suggestions with respect to changes in the log In requirements on E-filing Website


We wish to submit the following issues and suggestions for your kind considerations and favorable action:

Brief background of the issue

The department issued an advisory on 22nd September, asking taxpayers to furnish their latest information such as personal and secondary email and mobile phone numbers, address and bank account details. These details are then verified and processed after the taxpayer is sent a One Time Password (OTP) over the email and through SMS over the phone. This has been done to facilitate “effective communication” between the taxpayer and the department.

However, it is pertinent to note that for updating the details, one has to ensure that The mobile number and email ID are not used by more than 3 PANS. This requirement is causing immense hardship to a lot of people. While the taxpayers cannot question the government on such decisions. the citizens do have the right to bring to your kind notice the practical difficulties which don’t seem to hove been taken into. consideration before enforcing such a requirement.

Practical difficulties faced by the tax payers

There are multiple genuine reasons why one mobile number and email ID can be linked to multiple PANs and we take this liberty of giving a few examples:

a. In case of an individual, his mobile and email ID may be linked to his PAN as well as his parents’ PANs who may be super senior citizens. They do not have the technological literacy to create and check emails. Also, his details might have been used for his wife and children.

b. A person may be a Managing Director in a company and would therefore be signing that company’s return. His email ID and mobile would be used for that company’s PAN. The same person could be the Karta of his HUF and therefore, for the HUF’s PAN, the same email ID and mobile number would be used. The same person could be a trustee of a trust and therefore the same email ID and mobile would be linked to the Trust’s PAN.

In all such genuine cases, unfortunately, the login fails because the same email ID and mobile number are linked to multiple PANs.

Another problem that is being faced is that even in case of foreign assessees, at the time of logging in, the profile had to be updated. In that case also, the system is forcing the taxpayers to provide a mobile number. The foreign assessees does not have an Indian mobile number. in the ITR form also, this is not mandatory_ It is beyond our understanding as to how can the login requirements force the company to provide an Indian mobile number?


It is therefore very clear that introduction of such new procedural and technical requirements at a time when the entire nation is trying to cope up with the due dates under various laws, viz, Goods and Service Tax, Companies Act, Income Tax Act etc, puts additional compliance burden which could have been avoided.

Further, the details that are being sought by the Department are already available with the Income Tax Department and Therefore putting an extra compliance burden on the assessees at a time when the due date for filing the return of income and the tax audit report is fast approaching makes no sense.

A prior discussion with the tax paying fraternity before rolling out of such changes would have helped the cause. We therefore request you to kindly not put such additional compliance burden on the tax payers. Without prejudice to the some, we request you to kindly defer the aforesaid implementation after due discussion and deliberations with the tax payers and proceed only if the same is acceptable to one and all.

We hope you would be kind enough to consider our proposals for favorable action.

Thanking You,

Yours. Sincerely,

For, Chartered Accountants’ Association, Ahmedabad

Rajni M. Shah, Chairman, Legal & Representation Committee, CAA, Ahmedabad

Kunal A. Shah, President, CAA, Ahmedabad

Download official copy of Above Representation in PDF Format

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More Under Income Tax


  1. Sudhir Kumar Saxena says:

    Modi government is annoying many people, because he is filling all holesby which tax evador earlier escape. When the nuts are night there were a huge cry like demonetizatin but now is everything ok. Like that be calm have patience Modi will fill BHOOSA in all the tax evadors.

  2. avtar singh says:

    Department may receive the manual income tax return and the department staff may online/efilling self through their employees then public may relief from the email id/telephone no. then some people got service in income-tax Deptt.

  3. Alok Kumar says:

    The 25% growth in IT return in current year will certainly fall down in coming year as many people are not well versed with e-mail and small practitioner promotes them to file their return after providing their mobile no. at least. If the CBDT is thinking of proper service of notice through this procedure, they have misconceived the issue and confused.

  4. Vijaya Simha says:

    it is not acceptable and unable to understand their strategy. if they have time let them do some development things. let them not trouble the tax payers like this.

  5. HARJIT SINGH says:

    Modi Govt is LBDN (Look busy do nothing). Every economic step of the Government is useless and it put unnecessary compliance burden on Tax Payers. India has already gone backward by at least 20 years. If such trends are continued till 2019, I fear, the economic positions of India would be more worrisome. Well done Modi Ji, be continue and order for IT Returns also on monthly basis.

  6. Vijay Kumar says:

    In a close family, the Mobile nos. in many accounts are same, and owned by a responsible person, on whome the family member has full faith.
    2. Not more than 3 ACCOUNTS FOR A SINGLE PAN
    . If the First holder of the account is different, why this sort of restrictions by the Government, specially in a close family?

  7. prakasham says:

    The CBDT’s initiative of one mobile numbe one mail id is due to the bad practice of many Chartered Accountants and Income Tax Practitioners. I have seen many Authorised Representatives filing the Returns of Income of the assessees. If refund is to be received, the people keep flocking the Income Tax Offices. If demand is raised, it is becoming hell to collect. Most of the assessees give false addresses. The mobile numbers keep changing. The mail Ids given belongs to the Authorised Representatives. Then how will the Nation prosper.

  8. RAVI ARORA says:

    Already taxpayers are feeling heavy burden on their end. If the Aadhar card are linked then why this renewal process is required. This is unnecessarily burden on CA, Tax Practitioners, Accountants & Taxpayers. Government should more times in filing of GST Returns & Income Tax Returns

  9. s c shankar says:

    the department has made the linking of pan with aadhar compulsory. since the aadhar has captured the mobile no. address & emails of the individual if aadhar no is with the department then what is the neccessity to keep updating the particulars of the assesse each time.
    it is also convenient to update the latest particulars of a person at one place and and all govt agencies will be able to communicate with that person thus avoiding this cumbersome procedure.

  10. CA. S.C.Podder says:

    Comment : 1.On three changes on Income Tax Website WEF 22nd September 2017
    1.2 Open letter to CBDT on restriction on use Email and Mobile Nunber
    1.3 Open letter to PM related to income tax profile update on e-filing
    (Sources Tax Guru web sites)
    Further to my observation/ comments dated 23/09/2017, I wanted to draw further to CBDT, PM and all the users for e-filling via- Tax guru site which are briefly stated below “
    1.I am one of the active members of the Institute of Chartered Accountants of India , Presently my age is 76 years , and in the profession since last 47 years from the year 1970 , I failed to understand why the Income Tax Department and the Government of India are changing their policies frequently rather on daily basis ? It’s very difficult to cope / complied with by the common man . CBDT and the Government are saying “ we are friendly with the common man “ with respect to filing of his / her taxations returns , We the Chartered Accountants fraternity always trying to convinced people to co-operate with the Government , but Govt’ Itax department are thinking otherwise ( may be tax collections is not satisfactory as per desired level ) . But those who never filed Taxation returns have e-filed of their taxation returns .
    2. For filing Taxation returns one has to register with Income Tax Portal ( he needs to give his/ her Name , PAN card , AADHAAR card No. Mobile no, E-mail ID besides his / her financial details , Bank account Numbers , IFSC code Etc. Besides his/ her Residential details , Personal details etc. ( refer Income Tax Returns Forms ) after filing he / she have to Send ITR V to CPC – Itax Department in Bangaluru by speed post after their signature .
    3. The persons may not have one Mobile and e-mail ID which we created for them , forgotten the pass word and even does not know his mobile No. One need to get help from the professionals or otherwise.
    4. In the New systems one needs to alternate ( another mobile number and Email ID. ) which may not possible to get from them.
    5. Some persons have income from other sources ( Interest Bank Fixed deposit only ) Bank deducted Tax . he/ she need to get refund of Taxes Deducted , need to file Taxation returns , also need Two mobile no ( Alternate ) Email ID . He does not have any mobile , the question of Computer purchase does not arise .
    6. One may be head of the family / or Son/ daughter is able to e-filed on behalf of all using his / her Mobile no. and E-mail ID, including NRI family members, what is the harm in it ?
    7. so many and so forth points in this regard.
    8. Besides Taxation Returns (yet to be submitted after Tax audit )
    9. The director / CEO/ Karta of Family / Secretary of a society etc. are to file Taxation Returns on behalf of all.
    10. Whatever may be the intention behind it, you are harassing the Genuine Tax Payers.
    I should appreciate if the CBDT and PM reconsider this ideas .

    will be benefited .

  11. g c pramanik says:

    We all democracy like people should condemn the undemocratic process initiated by the white color job people and who do not have practical knowledge. they are not aware the percentage of computer literacy people.
    this trends and action of the CBDT would not help the nation in curbing the corruption rather would certainly harass the innocent people try to pay tax honestly. please realize it.

  12. N K MALHOTRA says:


  13. BARATHIDAON R says:

    The authorities are the cause for all mismatches. They are not using unambiguous terms while soliciting the data. This holds good even from writing our names in different forms.
    In the present case “Mobile number belongs to ” is highly confusing. Mobile number may stand in any of the family members name and exclusively used by other member.
    If the intention is to capture the subscriber name, “Mobile number subscriber name as registered with the service provider” should have been used.

  14. S Raju says:

    Your Letter is very Appropriate. Many I T assessess give the entire data to I T Practioners and contacting Phone nos are very difficult. More over Senior citizens are not used to mobile phone/email etc and it will be very diffuclut for the Income Tax Department to contact them.

    Hence, P M and Finance Minister to look into it and review this order.
    Will they do

  15. ANITA says:

    The mail id and mobile number used for 3 assessee decision should be withdraw. as a course of time many of people who do the business but does not come across the internet or computer, so if a C.A or consultant do the work on behalf of them , it will time consuming and gulshit work. so you may pl withdraw this provision


    When we register for signing up, the email id and mobile number are provided. Now Aadhaar is linked with PAN, mobile and Bank accounts also. It is ridiculous to restrict them to 3 only. The IT department should have proper and efficient analysts to pick up details from the ITR to gather all details and correlate with the database.


    no buddy put form of updation online than what doing cbdt they suspend all pan card lakh of lakh individual ?? no to submeet any thing and go to strike and oppose the rule by public than what do it department hang to public in rope untill death ?? it is foollish officers idea bringing for public

  18. I’m glad that the CA association has taken up the cause on behalf of the taxpayers.I do appreciate the progressive changes this government want to bring in, but its happening too fast with no proper infra in place.Its indeed sad that an genuine ordinary citizen has to face such hardship to fulfill his duties in complying with filing of his returns. Aadhaar centres not functioning and unable to cope with linking of mobile nos of people, efiling an issue so on and so forth. The need of the hour is to set things in place and move ahead with such changes. I’m sure linking of various data should be done by the department themselves as they have enough data as of date. Can not the department concerned go the extra mile rather than making us runabout with no end result. Even as of date professionals have been overburdened with their day to day functioning. Hard to get any queries addressed, Awaiting to do e filing of my family members though the reurns are uploaded way back in July.

  19. Ravindra Dave says:

    I tried to update the profile . the email id is used by 3 members of my family. Even so while submit clicking for updating the profile data with bank account details etc I got error message saying email id already used by 3 assesees use another email id. I think the system has bugs and confuses update profile with new registration.

  20. Chandrashekar says:

    Policy makers are absolutely have zero knowledge about ground realities.
    For new registration they are asking land line number too. Now days hardly anyone has landline. This means one has to buy a landline just for income-tax purpose. It is funny.

  21. Tiru Narayan says:

    I am a NRI. I do not have an Indian mobile number. I use my tax consultant’s mobile number. From this letter and other comments, I will have immense problems in just logging in to e-file.

    What is the reason for this change in login process? Can someone help me understand what is meant by “This has been done to facilitate “effective communication” between the taxpayer and the department.”? I already have a fairly effective communication. The Tax Dept. should make it easy to verify login credentials. As soon as we provide the user name and password, why can’t the system send me an email with OTP?

    Please make reasonable and sensible change(s).

  22. suresh paharia says:

    It is proved that, there are some people at CBDT, who lack practical knowledge about how things are handled at ground level . In one of my clients case in 8 companies and his wife are directors , what to do ?Take more mobiles ?How to keep track on various e-mail addresses ? This new procedur is imposed without any prior notification and and without any debate as to what is the problem in existing system .

    Is this the result of weak opposition ?

  23. Ashok D Chavhan says:

    Taxpayer never opens it E Mail and many times forget the E Mail ID and password ,they even do not know how to forward the OTP sent to their mobile and let over all this process ,they actually get panicked with messages received from IT department as viz Your ITR for particular A.Y is submitted successfully or ITR V received and immediately call on to the CA or practitioner in panic regarding the message on mobile

  24. Narender Kumar Goel says:

    I am CFO and Director in some companies being handled by me for Income Tax purposes. There are four such companies, beside my family members in four ( two of which are super senior citizens). I am responsible to file the Income Tax return for all these persons. With the new law, it has beome very difficult and I might have to purchase 2 more mobiles (already having one), just only for Income Tax purposes. This is not correct on part of CBDT amd makeing a difficult proposition for all such persons, who are regular in filing return and paying taxes on time and getting the asessment done on time. Even for this purpose I have been awarded Bronze medal by Income Tax authorities.
    I request CBDT to withdraw such notification and help hundered of charterest accountant who are on senior position or practising to avoide this hardship.
    CA Narender Kumar Goel

  25. Krishna Kumaran Nair.T.R says:

    It is evident that, there are some people at CBDT, who lack practical knowledge about how things are handled at ground level , while filing various Returns, Forms linking etc. Aadhaar linking fell into a mess. This new procedure was imposed without any prior notification and is going to create unnecessary delay in filing returns.

  26. Nirmal Pahade says:

    The department is adopting new compliance whereas the Schema version of form 29 B has not yet been notified. Due to this many company returns though ready cannot be filed. Will anyone look into this aspect of implementation?

  27. CA Premchand Kadmawala says:

    Now it is taken that the tax payers are Chors and are slave of the CBDT And Jetly Govt.Pass any order in the night and applicable from the mid night.
    Further whats the need to tell the mobile no linked to the Bank account.what ever action they want can be taken from the PAN as it is given in the return and the bank. Foolish orders.

  28. Tarunkumar D Trivedi says:

    Intention behind compelling taxpayers to update profile in return period is not understandable. Such type of information should be collected when work load is less.
    Previously single mobile no and email ID can be used for 10 persons. Now why it is changed.

  29. Kumar says:

    I am the director of five companies and i have filled individual return . And my wife has not used computer. She not having email id.. All companies used my mobile & Email id for Income tax communication and filled their return. Now CBDT changes update process. How i filled Income tax return in before due date. As Navratri utsav is going on after that Diwali Festival . And then Due date of 30th OCt. Diwali is festival which we growth our business. How we look our business if CBDT doing changes without any intimations

  30. Nageswara Dutt says:

    Insisting further registration and further insistence that not more than three mobiles should not be linked to PAN and also insistence of further bank details is nothing but the height of MADNESS. Bank details, email I’d; AADHAR and mobile number are already in IT return form. Government should stop this attitude and creating nuisance to public

  31. CA SAT PAUL says:

    In my profile I have put mail id and mobile number of some one else as my mail and mobile already in use for more than three person as applicable before amendment please let me know how it work as best communication between income tax department and assessee.

  32. Shastry V B says:

    Dept is forcing a person to have a mobile number, and email facility. Forcing is illegal. How about senior citizens, deaf, dumb, blind, persons staying at old age homes, etc.,

  33. Girishkumar J Patel says:

    We agree

    But at present, we are the poor assessee who has to bear all burden and such decisions

    There is no alternative at present, unless and until some co operative measures taken by government

  34. CA. S.C.Podder says:

    I being head of the family submitted my Mobile no and E-mail ID in the income Return form ( ITRs ) of my wife ( BOB – 01/1946 ) not able to handle computers and mobile ) and of my unmarried daughter working outside West Bengal,( the company has provided mobile and e-mail ID ) , as an when she left the services She will have to surrender his mobile and E-mail ID ) , hence in ITax Return I have given my mobile no . and e-mail ID. . My mobile no and Email ID have given in my Itax Return ( Thus three in numbers ) . Every persons in my family separate sources of Income and Bank accounts ( my it be Jointly or otherwise ) addresses of three of Us is same , During the last several years – we filed Taxation returns of three of us ( e-filed ) All the information from ITax department or CPC – are getting and complied with when ever necessary. It is not fair enough to give further details of Personal details Residential address etc including , bank account numbers ,Mobile nos linked with AADHAAR card . e-mail ID ‘s is same for three of Us, but while submitting Tax Returns all the mandated documents as per Tax Returns ( ITRs ) submitted and ITR – V , sighed by each one of us. while assessing e-filed portal every one has separate pass word, PAN numbers, AAdhaar card no. now we can’t able be access as per New Directive dated 22/09/2017 .
    I should appreciate if the CBDT consider to go back the old system to logon e- filling portal as proposed by the Ammedabad Chartered Accountants Association , we/ public will be benefited . I being one of the Chartered Accountants of the The Institute of Chartered accountants of India , ( Member since 1970 ) .
    We are shuttling after many matters including family and illness .. Again and again systems are changing with out any reasons .
    Please consider the Open letter to CBDT by the Association .
    You are saying Income Department is friendly with the Tax Payers in India. I don’t think so, at my age of 76 years ( in profession 47 years )
    Please accept the Proposal made by the association .

  35. R. K. Kotian says:

    Further a person may be secretary of various organisations, housing societies, a partner of a firm, a director in a company and is signing returns on various capacities. They should also bring in a law that one person, one capacity, one mobile one signature and that his mobile should not be used by any one else. They should also bring in a law that one person one bank account and all his monies should be kept in one bank. They should also make it mandatory not to have joint bank accounts. And many more such restrictions on citizens of this country. But no restrictions on those bringing in the regulations. They even forget that they strangulate the people in the process. They forget that the very same restrictions, compliances or rules will apply to them once they retire.

    Please bring in reasonable laws which can be predicted as reasonable and can be easily complied with. Citizens of this Country really love this country. The revenue which is received by the Government comes from them by way of voluntary compliance. Do not make their life miserable.

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