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 :-
23rd September, 2017
Central Board of Direct Taxes,
Ministry of Finance.
Government of India,
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.
For, Chartered Accountants’ Association, Ahmedabad
Rajni M. Shah, Chairman, Legal & Representation Committee, CAA, Ahmedabad
Kunal A. Shah, President, CAA, Ahmedabad