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Representation to FM on Remedial Measures for Glitches in the New E-Filing Portal
June 18, 2021

The Honorable Finance Minister
Ministry of Finance
New Delhi

Subject: Representation on Issues/Glitches in the New Income Tax Portal & Suggestive Remedial Measures.
Reference: Tweet dated 16.6.2021

Dear Ma'am,

With reference to the captioned subject matter, at the outset we convey our sincere gratitude and thanks to You, for taking due cognizance of the genuine difficulties and hardships of the taxpayers and their authorized representatives, arising out of certain issues and technical glitches in the new Income Tax Portal, and thereby giving us an opportunity to make this written representation to address this critical issue.

Accordingly, in this representation, we are making an honest and sincere attempt to practically demonstrate the technical glitches and currently non-functioning functionalities of the new e-Filing portal, so as to warrant an immediate and much needed attention of the concerned competent authorities to make the e-Filing experience, faster, smoother and better in real sense.

Representation to FM on Remedial Measures for Glitches in New E-Filing Portal

Practical Demonstration of the Improvements Needed in New e-Filing Portal

The following issued / glitches have been covered in this article:

  1. Slow Processing Speed
  2. Inactive e-Filing Tab for Filing ITRs for AY 2021-22
  3. Non-Availability of e-Proceedings Utility
  4. Non-Integration of Valid DINs
  5. Non-Availability of Previous Years ITR Forms, ITR Acknowledgements and All Other Online Forms
  6. Non-effective Tax Genie Autobot/Chatbox
  7. Non Availability of Online Forms 10A & 10AB for Filing Application for Re-registration of Charitable Trusts and similar Institutions
  8. Non Possibility of Revision of ITR & Other Online Forms
  9. Condonation Request only for ITR V
  10. Non Availability of Outstanding Demand Details prior to AY 2020-21

1. Slow Processing Speed

Slow Processing Speed

The most significant benefit or advantage of this new e-Filing portal has been proclaimed as its ability to process the ITRs as soon as these are filed by the taxpayers and thereby reducing the existing processing time period of 63 days by CPC to 0.

On first day, infact night (8:45 PM) of the launch of the new portal, it was not possible to even login to one's registered e-filing account. Though the login speed has improved in these 10 days of its launch, still a slight increase in traffic on site, makes the portal very slow with buffering and loading going on for few minutes even.

So, this slow processing speed of the new e-Filing portal is definitely a cause of concern. Currently the site is slow even when the peak return-filing season has not arrived and as such to cope up with the tremendously increased traffic during the peak filing season and more importantly to live upto its desired expectations of immediate processing of ITRs, it is quintessential to increase the speed and processing capabilities of the new e-Filing portal.

2. Inactive e-Filing Tab for Filing ITRs for AY 2021-22

The due dates of filing ITRs for the AY 2021-22 (FY 2020-21) in non-auditable cases has been extended from 31.7.2021 to 30.9.2021 and in auditable cases (other than transfer pricing) has been extended from 31.10.2021 to 30.11.2021 and in auditable transfer pricing cases has been extended from 30.11.2021 to 31.12.2021.

Inactive e-Filing Tab for Filing ITRs for AY 2021-22

However, currently the tab for filing ITR for the current AY 2021-22 is inactive and as such return filing for the AY 2021-22 is not possible presently.

Tab for filing ITR for the current AY 2021-22 is inactive and as such return filing for the AY 2021-22 is not possible presently

As soon as AY 2021-22 is selected by the user, the next mandatory tab “Select Filing Tab”, becomes inactive, thereby making it impossible to proceed any further.

It needs to be appreciated that the ITR filing work for AY 2021-22 will gain momentum after 30.6.2021, once the TDS Returns for Q4 of FY 2020-21 are being filed and corresponding TDS credit is being reflected in Form 26AS of the taxpayers. Thus, there is an immediate and urgent need to make the ITR filing tab for AY 2021-22 also functional and operational.

3. Non-Availability of e-Proceedings Utility

The newest and the brightest feather in the digital cap of the Income Tax Department i.e. the e-Proceedings utility was operating very seamlessly and smoothly in the previous e-Filing portal. The first season of the full-fledged faceless assessments for the AY 2018-19 has been successfully carried out on the previous e-Filing portal on the e-Proceedings utility.

However, inspite of the elapse of 10 days since its launch, the e-Proceedings utility has not been made functional in the new e-Filing portal yet. So, in the absence of the e-Proceedings utility, the taxpayers are not able to see and access any of their assessment, appeal and penalty proceedings notices and replies (faceless or otherwise).

It needs to be appreciated that though the time barring completion period for regular assessments u/s 143(3A)/144B for the AY 2018-19 has been extended till 30.6.2021, still the majority of these assessments have been concluded now or are in the final stages of conclusion. In many cases, the taxpayers have received scrutiny notices u/s 142(1) or show cause notices in cases of ongoing assessments or show cause notices for levy of penalty u/s 270A of the Incometax Act in cases of concluded assessments, on or before 31.5.2021, in the previous portal.

However, due to the unavailability of the e-Proceedings utility in the new portal, the assessees are not in a position to file their corresponding replies to such notices. Therefore, the e-Proceedings utility must be made functional in a timely manner, so as to enable the assessees to file their replies to the notices in a comfortable and appropriate manner and this black-out period starting from 31.5.2021 and continuing till date should be excluded from the time barring completion deadline of 30.6.2021.

Also, the user manual of the new e-Proceedings utility shows that the maximum up-loadable file size has now been reduced to 5MB in place of the earlier size of 10MB, which will create a lot of ground-level problems for the assessees to upload their supporting attachments and records along with their replies.

It needs to be appreciated that this new e-Filing portal was expected to be equipped with increased storing and processing capabilities and so instead of increasing the size of the up-loadable file, this decrease is certainly not warranted and called for.

 

4. Non-Integration of Valid DINs

The new e-Filing Portal in its present avatar is not capable of importing the Document Identification Numbers (DINs) of the orders, intimations, notices or any other communications.

One such instance is the consistent ‘DIN Error' being displayed in the Form 35 e-filing tab of the new portal.

Non-Integration of Valid DINs

Non-Integration of Valid DINs

Non-Integration of Valid DINs

The above Real-time windows of the new e-Filing Portal for filing Appeal Form 35 clearly show that even a valid DIN is not getting accepted by the e-Filing tab and thereby making it impossible for the assessees to proceed with filing their appeal Form 35 in respect of their assessment/re-assessment/penalty orders.

5. Non-Availability of Previous Years ITR Forms, ITR Acknowledgements and All Other Online Forms

Non-Availability of Previous Years ITR Forms, ITR Acknowledgements and All Other Online Forms

Non-Availability of Previous Years ITR Forms, ITR Acknowledgements and All Other Online Forms

Non-Availability of Previous Years ITR Forms, ITR Acknowledgements and All Other Online Forms

The previous years' ITR Forms and all other electronic Forms are currently not available for download. The ITR V Acknowledgements are being shown as downloadable but these don't get downloaded on clicking the download link.

So, currently the taxpayer is not having any access, whatsoever, to any of his/her previously filed ITRs, Appeals or any other Forms.

6. Non-effective Tax Genie Autobot/Chatbox

Non-effective Tax Genie Autobot/Chatbox

The widely publicized interactive autoboot TaxGenie chatbox feature of the new e-Filing portal bombards the users with prefilled questions and answers, many of which may not be even relevant to the specific query of the user. This feature is not actually an AI enabled feature but just a better presentation of the erstwhile Help sections of the previous e-Filing portal.

7. Non Availability of Online Forms 10A & 10AB for Filing Application for Re-registration of Charitable Trusts and similar Institutions

Non Availability of Online Forms 10A & 10AB for Filing Application for Re-registration of Charitable Trusts and similar Institutions

In the new e-Filing Portal, currently Forms 10A and 10AB for filing Applications for Re-Registration of Charitable Trusts and other similar institutions are not available inspite of the fact that the due date for filing such applications is 30.6.2021.

8. Non Possibility of Revision of ITR & Other Online Forms

Non Possibility of Revision of ITR & Other Online Forms

Non Possibility of Revision of ITR & Other Online Forms

 

In the new e-Filing portal, currently it is not possible to revise any of the previously filed ITR or any other online Form, as the ‘access denied' message makes it impossible for the assessee to revise his/her ITR or any other form.

9. Condonation Request only for ITR V

Condonation Request only for ITR V

Currently, only one type of Condonation Request has been enabled in the new e-Filing portal and that is Condonation for Delay in Submission of ITR-V. No other condonation request is possible.

10. Non Availability of Outstanding Demand Details prior to AY 2020-21

Non Availability of Outstanding Demand Details prior to AY 2020-21

Currently, the details of outstanding income tax demand prior to AY 2020-21 are not getting reflected in the new e-Filing portal and as such making it impossible for the assessees to file responses to their outstanding demands, and thereby giving a leeway for adjustment of their refunds against such demands u/s 245 of the Act.

Concluding Remarks

The above practical demonstration with the help of real-time templates of the new e-Filing portal makes it duly evident that inspite of the much hype and hoopla concerning this new e-Filing portal, in reality, practically an assessee can't file ITR for AY 2021-22, can't file appeal, can't file rectification or revision, can't access or see previous years ITR Forms and other online Forms, and doesn't have any access to any of the assessment, appeal and penalty proceedings, in the current version and avatar of this new e-Filing portal.

Ironically, this new e-filing portal in its current avatar, instead of facilitating the widely proclaimed progression to digitalisation is infact currently working in its reverse gear and is forcing reverting to manual filing, to avert non-compliance of specified deadlines, one such case in point being the relaxation given by the CBDT in e-filing of forms 15CA and 15CB for foreign remittances, in manual format to the authorised dealers till 30.6.2021.

Thus, the competent income tax authorities and the vendor Infosys are requested to take immediate consideration and cognizance of the above practically demonstrated technical glitches and non functioning functionalities to make the incometax e-filing experience faster, smoother and better in real and effective manner.

Thanking You and assuring You of our best professional support and contribution in Nation building at all times.

For M/s S M Mohanka & Associates

Chartered Accountants
- Sd -
Mayank Mohanka, FCA
Partner
M.No. 509020


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Category Income Tax, Other Articles by - Mayank Mohanka 



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