The update session focused on several key changes and enhancements in the Income Tax Return (ITR) filing process for Assessment Year 2024-25. Major updates included adjustments to bank account validation requirements for smooth refund processing. Effective from this assessment year, taxpayers must pre-validate their bank accounts on the e-Filing portal, as the option to select a refund credit bank account directly from ITR forms has been removed. Refunds will now be credited to one of the taxpayer’s pre-validated accounts. Moreover, the functionality to check refund status has been shifted to post-login mode, accessible under ‘Services -> Know Your Refund Status’.
Additionally, amendments were noted in statutory forms, specifically in Tax Audit Reports (Form 3CA-3CD and Form 3CB-CD) and related to Section 115BAE for new manufacturing cooperative societies. Notably, Clause 12 was amended to include reporting requirements for profits assessable under presumptive tax schemes.
In terms of e-proceedings, there were changes in downloading Section 245/245(1) notices, now available under ‘Response to Outstanding Demand’. The introduction of Form 34BC under the e-Dispute Resolution Scheme provided a structured approach for small and medium taxpayers to resolve disputes through Dispute Resolution Committees.
The session concluded with a comprehensive overview of common issues related to filing grievances, particularly concerning return and refund-related grievances. These include failures in return processing, delays in filing, and issues related to refund receipt and adjustment against outstanding demands. Attendees were encouraged to engage in a question-and-answer session to clarify any doubts or seek further information on the updated procedures and forms.
Agenda
1 Up-dation of ITR Forms for AY 2024-25
2 Changes in Bank Account Validation
3 Changes in Know Your Refund Status
4 Changes in Statutory Forms
5 Changes in e-proceedings
6 Common Issues in Resolution of Grievances
7 Questions and Answers
Updation of ITR Forms for AY 2024-25
Changes in Functionalities Bank Account Validation
> To ensure the smooth receipt of your Income Tax Refund, taxpayers are required to pre-validate bank account on the e-Filing portal. Income Tax refunds are issued to pre-validated bank accounts linked to PAN.
> From AY 2024-25 onwards, there are some minor changes in Prevalidate bank Account functionality: option of selection of bank account for credit of refund has been removed from ITR Forms. Refund will be credited to the pre-validated bank account of taxpayer (if multiple bank accounts are pre-validated then refund will be credited to one of the pre-validated bank accounts)
Verification of bank account with 6 digit OTP received on e-filing registered Mobile no. and E-mail id for Validation.
Changes in Functionality – know your Refund Status
“Know Your Refund Status” functionality is shifted to Post-login from Pre-login Mode. The functionality is available after login to e-Filing portal by navigating through Services -> Know Your Refund Status.
Message regarding shifting of Functionality
Changes in Statutory Form
Tax Audit Report in Form 3CA-3CD and Form 3CB-CD updated for AY 2024-25
Changes in Tax Audit Report for AY 2024-25
- CBDT has notified changes to the Form 3CD vide Notification No. 27/2024 /F. No. 370142/3/2024-TPL, dated 05-03-2024.
New Regime for Cooperative Societies
- Option for Section 115BAE is to be exercised by new manufacturing co-operative societies by e-filing Form 10-IFA on or before the due date specified under Section 139(1) for furnishing the first return of income for any previous year relevant to the assessment year commencing on or after the 1st day of April 2024 (AY 2024-25).
Clause 12 amended to include Presumptive Taxation on professional Income
- Amended Clause 12 requires the tax auditor to report “Whether the profit and loss account includes any profits and gains assessable on a presumptive basis, if yes, indicate the amount and the relevant sections (44AD, 44ADA, 44AE, 44AF, 44B, 44BB, 44BBA, 44BBB, Chapter XII-G, First Schedule or any other relevant section)”.
- There was no mention of Section 44ADA in pre-amended Clause 12. Section 44ADA contains special provisions for computing the profits and gains of the profession on a presumptive basis.
Clause 12 (Reporting of profits assessable under presumptive tax schemes credited to P&L)
Clause 18:Adjustment to WDV consequential to New Tax Regime
- With the amendment of Section 115BAC by the Finance Act, 2023, new tax regime is default regime with effect from the assessment year 2024-25.
Clause 32: Reference to Section 115BAE
Rule 12 has been amended to allow individuals and HUF who are liable to tax audits under Section 44AB to verify the return of income through an electronic verification code. Earlier, they could verify the returns only through digital signature.
New Form Introduced – Form 10-IA
Introduction to Form 10-IA
With effect from AY 2024-24 (FY 2023-24) Form 10-IA has to be furnished when deduction u/s section 80DD/80U is claimed.
These sections cover expenses incurred to treat a dependent person (or self) with a disability/severe disability subject to
pre-defined conditions. The deduction is the disability is certified by:
- A Neurologist having a degree of Doctor of Medicine (MD) in Neurology (in case of children, a Paediatric Neurologist having an equivalent degree); or
- A Civil Surgeon or Chief Medical Officer in a Government hospital.
Note: When the condition of disability is temporary and requires reassessment after a specified period, the certificate in Form no. 10-IA shall be valid for the period starting from the assessment year relevant to the previous year during which the certificate was issued and ending with the assessment year relevant to the previous year during which the Form 10 IA validity of the certificate expires
Filing form 10-IA
Click the tile- Persons without Business/ Professional Income and Select Form 10-IA
Select the Assessment Year
Enter the Certificate No., Date of issue and Name and address of medical authority, attach the Certificate and Submit
Changes in e-Proceedings
Option of download Sec 245/245(1) notices moved under Response to Outstanding Demand.
On response to outstanding demand page Taxpayer can also download the latest and earlier section 245 notices by clicking on buttons “Latest section 245 notice” or “Section 245 Notice issued earlier”
For downloading the notices issues earlier Tax payer can select the Financial Year for which he/she wants to download the notice and click on download button.
New Form 34BC introduced
e-Dispute Resolution Scheme, 2022
> The dispute resolution fora that small and medium taxpayers can opt to approach are the Dispute Resolution Committees to be constituted by the Central Government u/s 245MA read with Rule 44DAA.
> Small and medium taxpayers [those whose returned income is Rs. 50 lakhs or less [if return filed] who fulfil specified conditions can avail dispute resolution in respect of specified orders by making application to DRC.
> The Central Government has, vide Notification No. 27/2022 [S.O. 1642(E)], dated 5-4-2022], notified the new e-Dispute Resolution Scheme, under section 245MA. The Notification came into force with effect from 5-4-2022.
> Dispute Resolution Committee(DRC) is different from Dispute Resolution Panel (DRP) constituted u/s 144C.
Form 34BC- Taxpayer to login on Income Tax Portal and Navigate to e-file → Income Tax Forms →File Income Tax Forms →Form 34BC
In case there is dispute arising from any variation in the “specified order” (defined in Rule 44DAD), then taxpayer can file an application to the Dispute Resolution Committee ( DRC) by submitting duly filled Form 34BC online on the e-Filing portal subject to fulfillment of specified conditions (defined in Rule 44DAD).
Documents Required
Order against which Application is filed Panel Screen’. Section 143(3) is added in the section dropdown
Add details’ button is added and Section 143(3) is added under section and sub-section dropdown.
Statement of facts, Grounds of Application and additional evidence
Tax Paid on Returned Income
Verification
Common Issues while filing ITR
RETURN RELATED GRIEVANCES
Failure in processing of validly filed return of income (not processed within the due date) due to some technical reason not attributable to the assessee
As per Board’s Instruction No 5 of 2018 dated 21st Aug 2018 – window was provided till 30th Nov 2021.
To be approved by CCIT – To be communicated to Systems – Systems will enable processing of such returns.
Since time has not been extended beyond 30th Nov 2021, such cases are to be referred to the Board through proper channel.
06th December 2023
Notification: CBDT extends the deadline for processing claimed refund ITRs for AYs 2018–19 to 2020–21 until January 31, 2024
Condonation of delay u/s 119 (2)(b) of I. T. Act for filing return of income beyond the due date
> As per Board Circular No 9/2015 dated 09-06-2015 modified by Circular No 7/2023 dated 31st May 2023 Monetary limits prescribed.
> Condonation application should be made within 6 years from the end of the AY for which refund / loss is claimed.
> There should be a claim of refund or carry forward of losses to entertain such claims.
Claim of foreign tax credit in ROI
➢ Residents are allowed credit for any tax paid outside India by way of deduction or otherwise. Credit only for Tax Surcharge and Cess and not against Interest, Fee or Penalty.
➢ Form 67 to be furnished before the due date for filing ROI.
➢ There is no provision for condonation of delay in filing Form 67 by the Assessing Officer and the alternative remedy to file such an application before PCIT/CCIT/CBDT should be explored.
Form 67 due date for AY 2023-24
- The Central Board of Direct Taxes (CBDT) revised Rule 128 to provide that Form 67 can be filed on or before the end of an assessment year if the return of income for that year was filed within the time stipulated in Section 139(1) or Section 139(4).
- If the assessee has filed an updated return under Section 139(8A), Form 67 (related to income included in the updated return) must be filed on or before the date of filing of the updated return.
- The modification takes effect on April 1, 2022, and so applies to all FTC claims submitted during the fiscal year 2022-2023
Defective returns not processed and for that AO are not able to passed the order.
➢ The assessee will receive a detailed communication regarding the defective return filed along with the defects to be rectified.
➢ The assessee has to go to his E-filing Portal and rectify the defects mentioned by CPC and re-submit for processing.
Non receipt of Intimation order u/s 143(1)
The assessee can download intimation order from E-filing portal following path.
Login to E-Filing Portal → E-File → View Filed Returns → click on Download Intimation Order.
REFUND RELATED GRIEVANCES
Non-receipt of refund: Refund is determined for a particular A.Y. but there are outstanding demands for different A.Y.s or the same A.Y. under different sections (Penalty, 220(2) etc.)
Assessee has to submit response to the outstanding demand: Path: www.incometax.gov.in ->Login->Pending Actions-> Response to outstanding demand.
JAO also has to submit his response to the outstanding demand: Confirmation of demand through ITBA – recovery- menu- demand analysis- select recoverability status (A.Y. wise)- submit to CPC.
Non-receipt of refund: No outstanding demand but refund hold for 245
➢ Reason for refund failure such as PAN and Bank account name mismatch, invalid bank account number or IFSC Code (due to merger of banks) etc., is stated in the CPC communication.
➢ The assessee may be requested to update the relevant details in e-filing portal and then raise refund reissue request through his e-filing account login- services- create refund re-issue request.
➢ In such cases, no action is pending at the JAO end.
Non-receipt of refund: Refund determined; bank account validated by the assessee but refund failure.
➢ Assessee may be advised to update the bank account details once again: Delete the validated bank account and again add validated bank account through his efiling account.
➢ JAO to also update the bank details: Add assessee bank account through ITBA common function- menu-maintain bank account details and then inform assessee to raise refund re issue request through his e-filing account login- services- create refund re-issue request.
Refund determined but wrongly adjusted against an incorrect demand.
➢ Verify the details to ascertain whether the refund is adjusted against incorrect outstanding demand.
➢ If required, AO can pass rectification order.
➢ Upto A.Y. 2015- 16 rectification order can be passed in ITD for the A.Y. against which refund is adjusted.
➢ If the respective order for A.Y. is not passed through ITD / 400 Challan is not reflected while giving tax credits, then use manual order upload functionality in ITBA.
➢ For Assessment year 2016-17 onwards, pass Rectification order in ITBA for the A.Y. against which refund is adjusted. Up to AY 2020-21, Web Service is available. If 400 Challan is not reflected while giving tax credits, then use manual order upload functionality in ITBA. Path: Assessment- Menu- Manual order upload
Once manual order is uploaded then check for accounting status under list of manual orders. If accounting status is “accounting closed by CPC”, then only order is passed. In case of errors, raise ITBA Helpdesk ticket with error screenshots. Path: Assessment- Menu- List of manual orders.
Withholding/release of refund: (amended section 245(2) of IT Act, 1961 from 01.04.2023 as per finance act-2023)
Section 245(2) of the IT Act, 1961 allows assessing officer to withhold refund of the assessee with prior approval of the PCIT related to ITR selected for scrutiny through CASS.
Since CASS cases are handled by FAOs under faceless assessment, the FAO needs to take prior administrative approval of the PCIT(AU) and then communicate to JAO for withholding or release of refund. Communication from FAO will be received in official mail as well as ITBA- Faceless enquiry- Work list.
Once JAO receives communication from FAO, the JAO needs to take necessary action for withholding/ release of refund through ITBA – ITR Processing – Return Receipt Register-View RRR entries.
Refunds adjusted against correct outstanding demand, but the balance refund not released to assessee.
The AO needs to pass fresh rectification order for the year against which the refund challan is adjusted.
Upto A.Y. 2015-16 rectification order can be passed in ITD for the A.Y. against which refund is adjusted. If the respective order for A.Y. is not passed through ITD / 400 Challan is not reflected while giving tax credits, then use manual order upload functionality in ITBA.
For Assessment year 2016-17 onwards, pass Rectification order in ITBA for the A.Y. against which refund is adjusted. Up to AY 2020-21, Web Service is available. If 400 Challan is not reflected while giving tax credits, then use manual order upload functionality in ITBA. Path: Assessment- Menu- Manual order upload
Once manual order is uploaded then check for accounting status under list of manual orders. If accounting status is “accounting closed by CPC”, then only order is passed. In case of errors, raise ITBA Helpdesk ticket with error screenshots. Path: Assessment- Menu- List of manual orders.
Order u/s 154 passed determining refund through manual order uploading in ITBA but assessee has not received refund.
Once manual order is uploaded then check for accounting status under list of manual orders available in assessment module → Menu → List of Manual orders. Check for the status. If accounting status is “accounting closed by CPC”, then only order is passed. In case of errors, raise ITBA Helpdesk ticket with error screenshots.
Refund determined in intimation for AY:2008-09 but assessee has not received refund.
The Assessing Officer has to ascertain the reason for non-credit of refund. The reason may be as under
(a) The refund was adjusted against any outstanding demand: If the intimation order was passed in ITD, it can be checked in ITD(AST)—Processing. If the refund was adjusted correctly, the same can be intimated to assessee. If the refund was adjusted wrongly, rectification order for the AY in which refund was adjusted has to be passed.
(b) Refund not credited due to invalid bank account/non-encashment of cheque in time hence refund got blocked: The refund status can be checked from ITD(BCP) and reason has to be ascertained. Then AO has to validate the bank account or advise the assessee to raise refund reissue request accordingly.
Validation of Bank accounts in 1.0 and CPC 2.0 are different.
AO can only add bank accounts. The refunds will be credited only to validated bank accounts, which the assessee has to validate through his e-filing portal.
In Common function module → Menu → Maintain bank account details → Enter PAN → Click Add row and save the bank details Tick the column → Indicate the Bank a/c which you prefer to get refund credit.
Refund adjusted against outstanding demand for previous years. The assessee produces copies of challan regarding payment, but challans are not reflected in ITBA-OLTAS module.
Raise ITBA helpdesk ticket with Challan Details- BSR Code, Challan Sl. No. and Challan Deposit Date. Once challans are reflected, pass rectification order.
Now Floor is open for Questions
