Today many of compliances in Gst, Income Tax, Mca requires authentication of some Name, Pan & DSC which has made a hindrance in being compliant.
Few examples and How we dealt with the same
1. MCA requires to Update DSC when a new DSC is purchased & to authenticate it, it needs the First name, middle name, last name as given in the dir-3 originally and it should be accurate to the space also & some time the DIR-3 filled would be many years old and would be removed from files, this would result in trial and error in mca as no information is provided in mca din details
in such a scenario in dir 12 we could be able to find the name as given in the database but now after deactivation of DIN we would not be able to retrieve from dir 12 if it is deactivated.
And also similar Name authentication process was incorporated in DIR-3 KYC where the name should match with Income tax PAN and should be accurate otherwise the form would not be successful for pre-scrutiny ,we can find the same as 5th character of PAN is last name 1st character and other is provided name in income tax website for profile but the authentication of Father name was very difficult as in website we cannot find what’s in the database and in PAN card its given as only initials.
But there is a trick to verify what's the father name in Income tax website but selecting ITR-1 in the file return and selecting an option to prepare and submit online and go to verification tab and there you can find the full name and father name as given in the website
And similarly for professionals we need to update dsc in MCA when rec'd a new dsc and to authenticate we need to provide enrollment date, membership no, First name, last name as per ICAI records as given in PAN updation form provided by ICAI and if we have done a transposition error of single character MCA website will not allow to register the dsc and also if we find the wrong name and enter that it will not register as it doesn't match with Income tax Pan (Provided ICAI has given an alias for DSC name verification in Pan updation form but it is not considering the same)
Thus hindering the many forms in this compliance period for ROC like AOC-4 MGT-7 etc for all clients, we have put grievance in ICAI on e-sahayata but got no reply yet and it will be very difficult as first ICAI will update and ICAI need to send to MCA the info for updating leaving us in huge problem with our clients .and also there is no revision to PAN updation form by ICAI.
I hope that ICAI does the process in the earliest.
2. GST requires the same kind PAN name Authentication for every client while registering and If the name is not matched the form is not processed but before Income tax website used to provide details of first name and last name in Know your assessing AO but now it shows only whole name with some character redacted & Also for registered users who are required to intimate the authority of some charges in the structure or address or many other things we need to first update the name as per pan in non-core amendments and then only we can make changes to core amendments or the form would not process (under cases of pan card changed after registration)
Thus for the above issues we have to do trial and error and checking the 5th character and Income tax website ITR-1 as given above and use know your pan for trial and error
3. Income tax also requires the name while registering the first time and if the Pan card is relatively new its ok but if it old we cannot find the name details of the pan card now it becomes full trial and error now and we should check it by know your pan, epay or know your AO.
- Now the part of return authentication
- MCA uses mainly DSC for every form
- GST uses an option for users to use OTP / DSC (compulsory for companies)
- Income tax uses multiple option like net banking ,demat,addhar otp,ITRV & DSC
- TDS uses DSC only (without DSC it's very limited)
And each have there own emsigner which cannot run simultaneously and is being very inconsistent due to inherent nature of port allocated and mainly we have allocated different system for each type of authentication then also it provides error like restart emsigner and we have used troubleshooting steps like http://127.0.0.1:port number and it says refused to connect thus know that it's accepting the query but not in specific website, many times restarting works but its not the solution
Chrome and Firefox have already announced they will no longer support java based programs and emsigner is a hook (in programming) and it's very unstable.
I like the income tax Java utility for creating a signature file but its also not perfect, one needs to restart the utility after new DSC is attached to create a signature file and its also best for providing many options for authentication with adhaar otp, login with net banking etc.
GST is also good in a sense if you are not a company we can use otp to authenticate and which is also provided in email rather than waiting in the mobile.
MCA is least favorite with its pdf based software DSC authentication for every form (I know it is required due to separate legal entity thus needing an authorized representative) as the form keeps updating for validation or ascetic reasons and there is no software provider to keep up with form updations.
The main reason for telling some of the problems of these to create awareness, I know this will not reach to the voice of governments but we need a consolidation of authenticating measures and also name authentication can be an inclusive formula (excel formula =isnumber(search("*"&a1&"*") for inclusive and if result in true it should be authenticated)we can use single installation for all the emsigner across all website or create new type of authentication as given in income tax across all website.
We need systems in India that are robust and stand in last hour rushes like facebook or google or WhatsApp or youtube in a day that no can think of and why can't we incorporate such systems in for compliance websites which have 0% tolerance for downtime and use something like ubikey like dsc used by Google and cryptocurrency for identity authentication.
I hope this will bring awareness and help on how to tackle these issues these were issues I faced recently and how I overcame them
The author is a CA Final student having interest in software, have created many excel files for GST set off and reconciliation. He can also be reached at rajatsolanki1@gmail.com.
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