RECONCILIATION OF 26AS, AIS, TIS WITH BOOKS OF ACCOUNT AND ROI AND REMEDIAL MEASURES FOR CORRECTIONS TO AVOID TAX DISPUTES.

[DEV KUMAR KOTHARI]

Form 26AS is well known old report available on websites of IT department and linked websites.

Annual Information Statement (AIS) and

 Tax Information Statement (TIS) have been recently launched and need not much introduction for readers of this website. In case of need search on website of IT Department and  other  web search can be made.

Differences:

It has been noticed that there are mismatches in the above three statements on portal of IT Department in many cases.

Some are due to mistakes, duplication or omission in 26AS, AIS and TIS.

Some are due to timing differences like in case of saving bank interest accrued has also been reported by some banks though it has not been paid so does not appear in bank statement hence in our normal book keeping system for such interest.

There have been some cases of misreporting and wrong reporting  of Fixed deposits, MF , TDS etc. due to omissions and duplication and mistakes in data entry etc.

ROI already filed:

In respect to ROI already filed we need to make a review and in cases where due date is extended or time is available and ROI has not been filed, before filing of ROI these statements need to be reviewed, reconciled and to take remedial action for corrections.

Remedial actions

Remedial actions can be like:

Check books of account to find out and rectify any mistake of data entry, omission, duplication etc. and rectify the same.

Write to DG system through grievance or other means as may be provided to point out differences due to mistakes and request for correction in any statement and also request to ask concerned reporting party to make corrections.

Write to the reporting party like employer in case of salary differences,  bank, MF, DP, stock broker, tax deductor, tax collector ,  etc. to make necessary corrections.

Therefore, in case of ROI not yet filed and for which time is available, these measures can be taken beforehand.

While filing ROI for AY 2021-22 some points may require recheck, reconsideration in view of development in current FY  so current affairs having substantial impact, can be considered to revise policy in any such matter for ROI of AY 2021-22 also.

For example, decision about stock valuation, writing off of bad debts, not accounting of incomes which have become contingent due to extraordinary developments can have a telling effect on income of FY 2020-21 and 2021-22.

Extension of last date for filing of ROI:

In view of above difficulties, extension of last date for filing of ROI from 31.12.2021 deserve to be announced much earlier and not after 11PM on 31.12.2021.

New Rule for application and extension by AO:

As discussed in  the following article dated 09.12.2021  by author it is high time to re-introduce Rules and Forms for application and extension of last date for filing of ROI:

DESIRABILITY TO ALLOW EXTENSION BY ASSESSING OFFICERS without loss to assessee and revenue both – coming * back of old provision is need of hour in view of COVID19 and OMICRON related problems and similar other serious health conditions and other contingencies etc.

In that article problems due to Viruses and health problems were discussed, however, problem of mismatches in three statements and mistakes therein are also  important requiring extension of time. Unless timely reconciliations and corrections are made, it is likely to cause many cases of mismatch and tax disputes.