In recent years 26AS is turn out to be our base for preparing, filing, matching, Income Tax Returns. Instead of facing any mismatch consequences at a later stage after filing, we prefer, the data in 26AS should match. The problem is that the 26AS is everchanging data and information updating will undertake continuously and the last 26AS may or may not match with the Income Tax Return. To avoid this, I think the CBDT should declare that the 26AS as on 31st May of the respective year will only be consider for matching the data with the return, any change in 26AS thereafter will not be considered for CPC matching, otherwise 26AS will be a never-ending story. The data will hit the 26AS any time whenever submitted by the SEBI, Banks, Annual Returns, and in near future by provision stores.
THE MISMATCH AND CORRECTION
It is easier to be said than done and not practical at all with the shortest time available from the last 26AS, to the due date of return filing. Think, a small correction in TDS on interest, if to be done in Nationalized Bank, in Form 16 of Salary of a corporate where more than 1000 employees are working and mostly the TDS Returns are processed and filed at centralized level, the TDS returns correction to be made in the returns filed, the same is easier said than done. The consequences, mismatch replies to the CPC and watching the SMS like What’s up daily to ascertain whether any mail for mismatch received. For a single employee, a retired person depositor, it is impossible to get the correction done.
TO FIX THE TOLERANCE LEVEL OF ACCEPTANCE
I think the CBDT should consider these difficulties and decide the tolerance level of mismatch. An Income difference of Rs.20000/- and TDS mismatch of Rs.5000/- will be condoned, provided the TDS should not result in refund, to the extent of condone level, in such a case, even if the difference will be condoned, no refund will be granted, but you will relieve from mismatch replies. The Total TO of the GST matches with the Annual Returns GSTR 9, or GSTR 1 then the monthly difference will be condoned. The updating in 26AS after the due date of the filing of the return will not be consider for the matching.
HUMAN INTERVENTION IN CPC PROCESSING
The acceptance level, should be feed into the system for auto processing of the returns as well as for issue of notices u/s142(1). Unless, this is done, A notice might be issued for the difference of Rs.100/- asking for producing, replying, reconciliation with details, why such a difference arise. A pre intervention will also help to notify that, there are no provision of revision of the returns in the acts like GST. We will also note that humans run the businesses and not figures which matches every time. A pilot is required though there is provision of Auto Pilot.
TRACES: UNCLAIMED TDS CHALLANS
This situation may arise, if TDS is paid but, the challan is not trace or twice paid. In many cases particularly, Govt, Semi Govt, Board, it was observed, that the TDS is paid, return is filed however, the challan is not adjusted because of mismatch, when demand raised, the same is paid, resulting in Unclaimed challans. I think a simple method should be devised to adjust the unclaimed challan, at least from when the TDS data is on the system.
GST: NO PROVISION FOR REVISED RETURN
When there is provision for correction, revision of the returns in all the Tax Laws and Rules, All the courts, then it is surprising why there is no provision of revision of the returns in GST. For any amendment, you must wait, till the end of the year for Annual Return, where all the corrections can be made. Revision not necessarily means, intentional errors, miss statements, and to be seen as negative compliance, but should be seen as positive approach to reach the correct conclusion. I think, revision is a right of the stakeholders.
MCA: KYC, DIN, OF THE DIRECTORS
Every year KYC of the Directors irrespective of no change, and increase in formalities, though results in faster processing of the filing and requests, the filing of all matters increase the burden and day to day work of the stakeholders.
With so much computerization, online things, day in and day out updation in the respective sites, We the chartered Accounts find difficult to cope with the changes, and when we develop the confidence in site, the site eighter change or updated. It is better the CA firm in coming days, will require to engage a SITE MASTER in our office. Who has update himself about all these sites for filing, processing, and other requirements? We have also to appoint a MATCH MAKER, who also should be an expert in matching the data on various portals as well as the data prepared for filing. As the computerization of all the things turns the simple job in to an expertise field, it is to be seen, how much all this exercise, results in making compliance easier for the common man.
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