Representation regarding issues / glitches on new Income Tax Portal

Income Tax Bar Association, Ahmedabad (ITBA), and All Gujarat Federation of Tax Consultants (AGFTC) has made a representation regarding the issues / glitches on the new Income Tax Portal. ITBA &  AGFTC made made an attempt to bifurcate issues / glitches on new Income Tax Portal in major 5 parts, which may require attention at different levels and also there might be some modules and features in progress for development. The 5 parts are 1. Technical & Performance Issues, Issues with Data and Missing Data, Missing / Non-Working Modules, 4. Utility / Schema Related Issues and Non-Technical but Serious Issue. Read Full text of the representation below

ALL GUJARAT FEDERATION OF TAX CONSULTANTS
303, B wing, Pratyaksh Kar Bhavan,
Nr. Panjrapole, Ambawadi, Ahmedabad-380 015
Ph.: +91 98255 65282
e-mail : [email protected]
website : www.agftc.in

INCOME TAX BAR ASSOCIATION, AHMEDABAD
Room No. 40, Aayakar Bhavan,
Navrangpura, Ahmedabad – 380 009
Ph.: +91 98250 72194, 079 4801 1947
e-mail : [email protected]
website : www.incometaxbar.org

To,
Mrs. Nirmala Sitharaman
Union Finance Minister of India
15, Safdarjung Road,
New Delhi – 110029
e-mail ID: [email protected]

Date: 18^th June, 2021

Respected Madam,

Subject: Representation regarding the issues / glitches on the new Income Tax Portal

Reference: Tweet by the official handle @nsitharamanoffc dated 16^th June, 2021 inviting representations

First of all we want to thank you for your tireless efforts to make the tax administration better and totally digital, which will be definitely a milestone for taxpayers and taxation consultants of the entire nation. We are sure that the Income Tax Portal 2.0 will change lot of things and be a positive driving force in increasing taxpayers base, bringing more transparency and honoring the points mentioned in taxpayers charter.

We also want to thank you for your concern and active efforts for participation from taxpayers and taxation consultants as the stakeholders in the development of new Income Tax Portal 2.0 and inviting the representation regarding the issue / glitches on it.

ABOUT THE ASSOCIATIONS:

Income Tax Bar Association, Ahmedabad (ITBA) is one of the first professional association founded in 1947 comprising of Tax Professionals, Tax Advocates and Chartered Accountants based at Ahmedabad and having current strength of more than 1100 members.

All Gujarat Federation of Tax Consultants (AGFTC) founded in the year 1992, is the apex Regional Body of Advocates, Chartered Accountants & Tax Practitioners of Gujarat, having membership strength of more than 1500 professionals and institutional membership across 37 districts of Gujarat.

Above associations are non-profit organizations of Tax Practitioners having membership of many Senior Tax Professionals, who regularly appear before ITAT, High Court and Supreme Court. The prime objective of these associations is not only to work for the cause of its professionals but also educate the public at large and to act as a catalyst between Citizens & Government Authorities.

DETAILED REPRESENTATION:

We have tried to collect and compile the issues reported by our members and experts. Also we have made an attempt to bifurcate it in major 5 parts, which may require attention at different levels and also there might be some modules and features in progress for development. The 5 parts are:

Part 1. Technical & Performance Issues

Part 2. Issues with Data and Missing Data

Part 3. Missing / Non-Working Modules

Part 4. Utility / Schema Related Issues

Part 5. Non-Technical but Serious Issue

The details are as under.

PART 1. TECHNICAL AND PERFORMANCE ISSUES:

1. Size of Webpage / Loading the Home Page:

The size of the home page of the new portal is too high and it takes high time to load the website even on the broadband & fiber connections. As you are already aware that even today India’s major internet penetration is mostly through mobile phones only and speedy and stable internet connection is not available to many parts of the country.

Also we contacted few technical people who are in the field of web development and got the tests done through the common, free and reliable tools to find out the overall performance related indicators of the new portal. We used (a) Google PageSpeed Insights, (b) GTMatrix & (c) SEOptimer services; and the major findings were:

(i) The page size is too large due to JavaScripts and Others

(ii) Fully loaded time is more than 14ms

(iii) Performance is sub-par

For details, we have provided screenshots of the same as annexure 1 to this representation.

2. Pages become unresponsive:

The pages inside new portal like profile, updating details etc. takes very high and long loading time on any random page, which may run into minutes and then the page becomes unresponsive.

3. Session Timeouts:

Whenever the page keeps loading for more than normal time, which generally is more than a minute, in general the only available option is to refresh the page through browser. The new portal in such scenario, shows session timeout when page is refreshed through browser. Most surprising part is, while trying to login again after this issue, a message appears that the previous session is running!

4. Chrome v. 91 related issue:

The new portal doesn’t show the login / register buttons on the top right when opened with Chrome Browser version 91 (checked with Version 91.0.4472.106). Now on most of the PCs Chrome updates automatically. Also such things can’t be expected from portal meant for future.

5. Weak User Interface:

User Interface is the major downside of the new portal, to list a few:

–  Home page is quite lengthy, have to keep scrolling more and more

– Huge rectangles / boxes for providing details, with so much blank space around it in most of the pages, but still the rectangles do not provide details at first glance. For details, which were visible in single line on old portal, one has to open the box. There is a option to show data in lines, but that too is equally inefficient

–  Very less details are available in a page. e.g. ITR history has only 3 ITR details in a page, most of page remains blank but for getting more data, one has to move to new page. Result: More time in a Login, more page loading.

– While filling an online form (say ITR) one has to pass through multiple pagesand many unnecessary validations, which consumes time and makes process cumbersome.

– Movement across website needs usage of mouse. Use of mouse reduces speed of working. Income Tax Portal is not a social media website. It must be a operational treat rather than visual treat.

–  When data is spread in many pages, and still so many modules to come, just imagine the level where one will have to travel through multiple pages for getting few details!

–  Static password exact functioning has not been demonstrated.

6. embridge (DSC Utility)

Installation of embridge clashes with embridge of DGFT portal. The signer should have a unique name and separate folder by default.

Also as taxation practitioners, one thing needs to be highlighted and needs serious attention from Government side. Currently different government portals use different versions of signers on different ports to enable use of digital signature. Currently MCA, TRACES, GST, DGFT & now new IT Portal using different ports and utility powered by eMudhra. The TIN NSDL and Guj RERA portals uses different versions of PKI components by (n)Code. Now for a tax professional, who works on multiple government portals, it may not be easy to technically set-up and run each utility without glitches and it consumes lot of time. A serious thinking and a viable technical solution is need of the hour.

7. Overall Experience and Testing

– The overall experience of portal on most of the pages is with glitches and random behavior. With so many issues faced right from 7^th June till today, it seems like one of the major function – testing – which is part of any product lifecycle is not performed properly.

– Looking at current glitches and speed of portal, with so many data related issues being flagged, we are afraid that the portal might not be able to handle multiple logins, which will be in millions in peak filing season.

– The current design and option to file the form inside the login page of the portal will make users to keep logged in for a longer time. This will require proper site functioning and continuous monitoring so that simple things like filing ITR do not become a troublesome work.

PART 2. ISSUES WITH DATA AND MISSING DATA

2.1 ISSUES WITH DATA

1. In Tax Consultant (CA) login, in profile, GSTIN is a mandatory field, which shouldn’t be a mandatory field.

2. Some users are facing difficulties where Gender is Changed or PAN / Aadhar linking status is not showing.

3. Data feed from TRACES to new portal is incorrect. e.g. Form 16 generated correctly from TRACES portal. However Gross salary and other income figures which are auto populated in employee login JSON files are doubled figures and are incorrect.

4. ITR Acknowledgement PDF download with 0 KB, i.e. not usable.

5. Refunds were approved in March but now showing as under process.

6. Returns which were processed in March are now showing as under processing.

7. Newly incorporated companies or firms are not able to register themselves, showing them as “minor”. By the way, minors too need to file return as per provisions of the act.

8. Forget password option is not working.

9. DIN Number not getting auto populated.

10. Challan Numbers not getting validated.

11. Showing mismatch in PAN & Aadhaar Data, where there is no technical mismatch.

12. UDIN is also not able to update for last month audit and other certification.

13. Bank Account number and IFSC are unnecessary and excessively masked. e.g. A person has one account in HDFC Bank. Now he changed his branch, account number is same. The portal is showing Bank as HDFC Bank, Account Number as xxx xxx xxx 1234 & IFSC as HDFC0xxxxxx. How to identify which one to keep?

14. Already pre-validated bank accounts needs to be pre-validated again.

15. GST Turnover not showing in 26AS.

2.2 MISSING DATA / DATA NOT REFLECTED

1. Old Demands

2. Old Grievances

3. Intimation Orders

4. ITR for older Assessment Years from 2007-08 to 2012-13

5. ITR PDF files (Only ITR V & XML showing available)

Missing data & issues with data is causing genuine hardship and has disturbed normal functioning of businesses and few other works.

e.g.

– Unavailability to download ITR is making it difficult for banks and customers for loan processing.

– Those who were supposed to e-verify ITR in 120 days might miss the time limit.

– Response to notices u/s 153C may require older ITR for AY 2011-12 / 2012­13 too, which are not available.

– Notices are received but details required to answer notice couldn’t be fetched from portal.

PART 3. MISSING / NON WORKING MODULES

1. DSC Registration in Tax Payer, Tax Consultant, Tax Deductor all logins

2. Form 10A & 10B for Charitable Trusts

3. Form 15CA / 15CB

4. Vivad Se Vishwas Scheme Tab

5. E-Proceedings

6. TDS Return Filing

7. Refund Re-issue

8. Rectification of Returns

9. Outstanding Demand & Response to Demands

10. Link / Utility to check applicability u/s 206AB / 206CCA

11. Condonation of Delay

Missing modules are required on priority basis as it is hurting business functions already hurt by Covid lockdowns and restrictions. Few of the examples are –

– Trust re-registration due date is 30^th June, 2021 but module is not available.

– VSV process is stuck in absence of VSV module, again time limit is there.

– Though manual 15CA / 15CB allowed later, they are one of the most important documents for importers.

– Assessees get notices from department even in this period of portal not working, with time limit mentioned. In absence of facilities like e-proceedings, it is impossible to comply.

– 206AB / 206CCA / 194Q etc. is having multiple data check conditions. In absence of proper utility to check the same, assessees have to rely upon declarations from other party, which is time consuming and inefficient way. It is being implemented from 1^st July, 2021.

– Without DSC registration most of things do not work. DSC registration pages do not open at all in Tax Consultant login.

PART 4. UTILITY / SCHEMA RELATED ISSUES

1. In Auto fetched data, in few cases it was found that the details are not as per profile or database of e-filing portal. e.g. Address.

2. The process of filing return is too long, even a simple ITR 1 takes much more time. Also the Desktop Utility communicates directly with portal. No option to save half saved work.

3. The JSON Schema File for various ITRs given by the ITD itself is having errors. While parsing the JSON schemas, errors occur because of missing comas etc.

4. The Desktop Utility given by the ITD does not have the facility to IMPORT other JSON files generated outside the utility.

5. The Desktop Utility given by the ITD this year is difficult to operate compared to the JAVA / Excel utilities given last year. JAVA / Excel utility used to have separate tab pages for each module which helped to iterate within the document and to any modules.

6. ‘Third Party software Registration’ is NOT available, which was available till last year, because of which the JSON files for ITR – 1,2,3,4,5,6 & 7 cannot be generated by other software developers as the Software ID, Secret Key and Iterator Count is NOT available for generating the ‘Digest key’ for the JSON file.

7. Structure of certain annexures for all ITRs are same for ITR – 2,3,5 and 6. However different structure are found in JSON schema. e.g. the Sch. HP is asking for Property Address once in 2,3 and 5, but wants address in Array (multiple address structure) for ITR 6.

PART 5. NON TECHNICAL BUT SERIOUS ISSUE

It has been reported by multiple assessee and consultants that even during the period of portal closure, portal not working, missing option to file returns for older year in response of notice and absence of e-proceedings module, they have got notices from department with time-limit. In absence of modules to even communicate, the assessee or representative cannot take any action and in few cases even orders passed and communicated.

Such incidents needs serious and immediate attention as this is injustice to the assessee and also it will drag assessee into litigation unnecessarily, which will further increase cost too.

REQUEST

Income Tax 2.0 is a future facing development. Also this portal is key in getting substantial revenue of the exchequer in form of direct taxes. Development of the same needs to be done carefully when the same is moving from one already existing database to another database. Also as the entire system from filing to assessment and appeal is entirely online, it becomes very difficult to comply with the same in case the platform (i.e. portal) doesn’t support.

Being stakeholders, it is our sincere request that such implementation should not be made in hurried manner without proper testing. We, as stakeholders are ready to support the Government in beta testing phase where large testing population is required.

In a year, already delayed due to second wave of Covid and stringent timelines for filing ITR & assessments as per amended provisions of the Act, much time is wasted in the starting of the year. In AY 2020-21, the filing timelines were disturbed due to nationwide lockdown. It should be avoided in AY 2021-22 so that from AY 2022-23, everything can be normal once again. The glitches and technical issues with new portal will be proved as speed breaker in the process, if not resolved quickly and immediately. Also along with resolution of issues, proper functioning is equally important.

We have already worked on the old portal which was one of the best examples of digital governance for a decade. It used to be an excellent platform which users loved. The expectations from the new portal are quite high. The experience of GST portal even after Four years of implementation adding fuel to the worries of the taxpayers and taxation professionals.

With hope for a best possible and long term solution,
Thanking You.

Yours Truly,

Adv. Bharat L. Sheth  
President AGFTC

Adv. Mrudang H. Vakil
President ITBA

CA Vishves Shah
Hon. Secretary AGFTC

CA Shridhar Shah
Hon. Secretary ITBA

Adv. Dhiresh T. Shah
Chairman Rep. Committee AGFTC

Place: Ahmedabad

ANNEXURE 1: PERFORMANCE RELATED INDICATORS

(a) Google PageSpeed Insights

For Desktop

Field Data – The chrome user Experience does not have sufficient real-world speed data for this page.

Origin Summary – Over the previous 28- days collection period, the aggregate of all pages served from origin does not pass Core Web Vitals assessment. To view suggestions tailored to each page, analyze individual page URLs.

Lab Data 

Values are estimated and may vary. The performance score is calculated directly from these metrics. See calculator.

Diagnostics – More information about the performance of your application. These numbers don’t directly affect the Performance score.

• A Avoid enormous network payloads — Total size was 61,939 KiB
• A Serve static assets with an efficient cache policy — 169 resources found
• A Avoid an excessive DOM size — 4,947 elements
• Ensure text remains visible during webfont load
• Does not use passive listeners to improve scrolling performance
  A Image elements do not have explicit width and height
• Minimize main-thread work — 3.7 s
• Reduce JavaScript execution time — 1.5 s
• Avoid chaining critical requests — 109 chains found
• Keep request counts low and transfer sizes small — 196 requests • 61,941 KiB
• Largest Contentful Paint element — 1 element found
• Avoid large layout shifts — 5 elements found
• Avoid long main-thread tasks — 6 long tasks found

Passed audits (22)

• Properly size images
• Defer offscreen images — Potential savings of 454 KiB
• Minify CSS — Potential savings of 3 KiB
• Minify JavaScript — Potential savings of 215 KiB
• Reduce unused CSS — Potential savings of 73 KiB
• Reduce unused JavaScript — Potential savings of 184 KiB
• Efficiently encode images
• Serve images in next-gen formats — Potential savings of 211 KiB
• Enable text compression
• Preconnect to required origins
• Initial server response time was short — Root document took 390 ms
• Avoid multiple page redirects
• Preload key requests
• Use video formats for animated content
• Remove duplicate modules in JavaScript bundles
• Avoid serving legacy JavaScript to modern browsers — Potential savings of 9 KiB
• Preload Largest Contentful Paint image
  User Timing marks and measures
• Minimize third-party usage — Third-party code blocked the main thread for 0 ms Lazy load third-party resources with facades
• Avoids document .write( )
• Avoid non-composited animations

(b) GTmetrix

(c) SEOptimer

Download Representation regarding issues / glitches on new Income Tax Portal in PDF Format