TAN Registration Number : What to do if it is forgotten or lost
What is a TAN Registration Number( TRN)
- TIN web site provides for registration of TAN by deductor , which is necessary , among other things, for downloading consolidated fvu file, Form 16A text file.
- When a deductor applies for TAN Registration online , a confirmatory email is sent giving 12 digit TAN Registration Number. Example :
“The TAN has been successfully registered on 31th October, 2009. Your registration number is T20098776DAC”
Where is TAN Registration Number needed
- TRN is required to be quoted in all correspondence with NSDL
- The following files are emailed by NSDL / available for download are password protected and the password is TRN
- Reset password
- Form 16A
Hence if TRN is lost, it is not possible to access downloaded Form 16A files
What is the procedure to retrieve TRN
- A written request on the letter head has to be sent to NSDL mentioning name of Deductor, TAN and requesting for retrieving TRN
- The letter should be signed by ‘Managing Director’ or ‘Chief Financial Officer’ or authorized signatory in the organization along with name and designation and should be preferably digitally signed
- If the letter is not digitally signed then one the following support documents will have to be provided
- Board resolution certifying the authorized person list, which includes the name of the authorized person.
- If name of the person is not present in the board resolution then supporting documents from ROC website mentioning name of the authorized person, Power of attorney or any other legal document authorizing the person to sign documents on behalf of the entity
- An undertaking on the letter head owning responsibility in case of misuse of login. Format of the undertaking is given at the end of this post
- Latest copy of Provisional Receipt Number
After receipt of above documents, the TRN will be emailed to the deductor.
Error in challan : New mechanism for correction
Deposit of TDS can be made either electronically or by a physical challan. e-Payment of tax is mandatory for companies and others covered under mandatory tax audit. Several times, while depositing tax, errors may creep in. To rectify these errors, income-tax department has issued new guidelines effective 01-09-2011.
This new mechanism allows Banks to correct physical challans only.For correction in electronic challan, request will have to be made to Assessing Officer.
Correction in Physical Challans
What fields can be corrected by bank
- Assessment Year
- Major Head Code
- Minor Head Code
- TAN/PAN
- Total Amount
- Nature of payment (TDS Codes)
What is the time frame for correction request ?
- Request for correction has to be made within 7 days of deposit of challan for correction in PAN, TAN and Assessment Year
- For Major head, minor head and nature of payment, request can be made within 3 months of deposit of challan.
What is the remedy available after time frame is over ?
- After lapse of time frame, request can be made to the Assessing Officer.
What is the time frame given to bank to carry out correction?
- After receipt of request, bank must carry out the correction within 7 days
What are other conditions for correction ?
- Correction in name is not allowed
- Any combination of correction of Minor Head and Assessment Year together is not allowed
- PAN/TAN correction will be allowed only when the name in the challan
matches with the name as per the new PAN/TAN. - The change of amount will be permitted only on the condition that the
amount so corrected is not different from the amount actually received by the bank and credited to Govt. Account. - For a single challan, correction is allowed only once. However, where 1st
correction request is made only for amount, a 2nd correction request will be allowed for correction in other fields. - There will be no partial acceptance of change correction request, i.e. either all the requested changes will be allowed, if they pass the validation, or no change will be allowed, if any one of the requested changes fails the validation test.
What is the procedure for requesting correction ?
- The tax-payer has to submit the request form for correction (in duplicate) to the concerned bank branch.
- The tax-payer has to attach copy of original challan counterfoil.
- In case of correction desired for challans in Form 280, 282, 283, the copy of PAN card is required to be attached.
- In case of correction desired for payments made by a tax-payer (other than an individual), the original authorization with seal of the non-individual taxpayer is required to be attached with the request form.
- A separate request form is to be submitted for each challan.
Correction in Electronic Challans
- For correction in electronic challans and for correction after the time period for application to bank lapses, a written request in prescribed format has to be made to the Assessing Officer
- Assessing Officer has power to rectify the error , in bona fide cases, to enable credit of tax to assessee
What is form of application to bank ?
income-tax department has given a format in which application can be made to the bank. The form is given in pdf format below
TDS Default Notices : How to avoid Interest Defaults
Each e-TDS statement is processed by TIN and defaults are put on web site for deductors to rectify.
In this article, we will examine what is default on account of interest and how it can be avoided
When is interest payable ?
As per income-tax , interest is payable under the following two circumstances
- Tax is not deducted , when it was deductible
- Tax once deducted, is not paid on or before due date
When tax is to be deducted
| At the time of credit or payment, whichever is earlier |
| 193- Interest on securities |
| 194A- Interest Other than “Interest on securities” |
| 194C- Payment to contractors / sub contractors |
| 194D – Insurance commission |
| 194H – Commission or Brokerage |
| 194G- Commission on sale of lottery tickets |
| 194I- Rent |
| 194J- Professional or technical fees |
| Before making payment or distribution |
| 194- Dividend |
| At the time of payment |
| 192- Salaries |
| 194B- Winning from lotteries / crossword puzzles |
| 194BB Winnings from horse races |
| 194EE – Payment from National Saving Scheme |
| 194F Payment for repurchase of units by UTI / mutual funds |
| 194LA: Payment of compensation on acquisition of certain immovable property |
What is the Due date of deposit of TDS ?
- All the TDS deductions made during a month are to be paid on or before7th of the next month. Example : All deductions made during April ,must be paid on or before May 7th, 2010.In case 7th of the month happens to be a Sunday or a bank holiday, then the payment can be made on the next business day.
- Beginning FY 2010-11 ,for deductions made during the month of March, payment must be made on or before 30th April.
What is the rate of interest ?
W.e.f 01-07-2010
- From the date when TDS was deductible till date of actual deduction,rate of interest is 1% p.m.
- For delayed deposit, from date of deduction till actual date of payment, rate of interest is 1.5% p.m
Prior to 01-07-2010
- From FY 2006-07 onwards for delayed deposit, from date of deduction till actual date of payment, rate of interest is 1.0% p.m
What is the due date of payment of interest ?
Interest must be calculated and paid before filing of eTDS statement of the quarter.
| Quarter 1 | Jul-15 |
| Quarter 2 | Oct-15 |
| Quarter 3 | Jan-15 |
| Quarter 4 | May-15 |
How is interest to be calculated ?
- Interest is to be calculated for every month or part of a month comprised
in a period, any fraction of a month shall be deemed to be a full month - The amount of tax, penalty or other sum in respect of which such interest
is to be calculated shall be rounded off to the nearest multiple of one
hundred rupees and for this purpose any fraction of one hundred rupees
shall be ignored and the amount so rounded off shall be deemed to be the
amount in respect of which the interest is to be calculated.
Of course, those using TdsPac software from Fast Facts need not worry. Automatic and accurate calculation of interest is available in single click.
Example of Interest Calculation
| Date Of Payment | Date of Deduction | Due Date | Date of Deposit | Delayed Deposit | Delayed Deduction | ||
| Months | Rate | Months | Rate | ||||
| 05/04/2010 | 05/04/2010 | 07/05/2010 | 09/05/2010 | 2 | 1% | - | - |
| 10/04/2010 | 10/04/2010 | 07/05/2010 | 09/05/2010 | 1 | 1% | - | - |
| 02/07/2010 | 04/08/2010 | 07/09/2010 | 07/09/2010 | - | - | 2 | 1% |
| 02/07/2010 | 04/08/2010 | 07/09/2010 | 15/09/2010 | 2 | 1.50% | 2 | 1% |
Avoiding Interest Default
To avoid interest default
- Deduct tax at source in time
- Deposit TDS by due date
- In case of delayed deduction / deposit ,calculate interest and deposit the same
- Show such interest properly in eTDS statement
Rectifying Interest Default
- You may download default notices after logging into your TAN account.
- Default Notice is a plain excel sheet without any password protection
- If there is any default on account of non-payment or short payment of interest, you need to pay up the same
- After paying , you have to file correction statement by including the interest payment challan.
Processing of eTDS Statement Begins
Income tax department has started processing of each and every eTDS statement in terms of section 200A. If there is any default, the same is available in the TIN web site.
How to view the defaults
- Visit www.tin-nsdl.com
- Login->TAN
- Click “Default”
- You will be able to view a table containing Financial Year, Form No, Quarter and a link to download file containing defaults
File format
- If the number of records is small, the file is in Excel format and without any password
- If the number of records is very large, the file is ^ delimited text file and a format is given.
Various defaults
- The file contains three type of defaults
- Short Deduction
- Short Payment
- Late Payments
- Each of the above is discussed in details
Analysis done by Fast Facts
Fast Facts team has done detailed analysis of several notices and the findings are given below for the benefit of our readers.
Late Payment Cases
- For each deductee record, date of deduction is displayed
- Due Date is worked out based on Provision and Non-Provision transactions
- Late Payment interest amount is calculated as per provisions of income-tax Act and Rules
- There is a column “Interest on Late Payment of Interest” , which is not filled. Possibly in future , this will also be calculated and shown
- If any amount of Interest is paid thru challans, the same is deducted from total interest and remaining amount is shown
Short Deduction Cases
- Short deduction = Amount deductible as per Tax Rate Flag Less Amount deducted
- For a deduction record “Tax Rate Flag” is shown as follows
“P” – Tax deducted at prescribed rate as per Income Tax Act
“L” – Tax deducted at lower rate as specified in the return. For sections having sub-sections, tax rate basis is assumed to be “L”
“H” – Higher Rate
- Based on “Tax Rate Flag”, amount deductible as calculated is shown
- Amount deducted is subtracted from amount deductible to show “Short Deduction Amount”
| Date of payment | PAN of the deductee | Section code | Tax rate flag ** | Amount paid | Amount deductible (A) | Amount deducted (B) | Short deduction amount (C) |
| 28-Jul-08 | 194J | P | 19950.00 | 2054.85 | 2009.00 | 45.85 | |
| 10-JUL-10 | BDDPS2497R | 194J | H | 6000.00 | 1200.00 | 600.00 | 600.00 |
Above two cases are explained in detail
- In the first case, Amount deductible is worked out by applying applicable rate of 10.3% on Rs. 19950 = 2054.85. Actual amount deducted is Rs. 2009. Hence there is a short deduction of Rs. 45.85.
- In the second case, everything appears to be correct. But the PAN given is not found in the income-tax database. This is reflected in “Tax Rate Flag” – H. Hence a penal rate of 20% is applied to Amount paid to arrive at amount deductible.
- Fast Facts team also found that such cases where PAN is not found in income-tax database, Form 16A is also not issued by the TIN system.
Short Payment
- These are simple cases, where amount deposited is less than amount deducted
In a separate article , Fast Facts Bulletin will explain what corrective actions are to be taken in response to the defaults and what precautions to be taken to avoid generation of such default notices.
How to download Form 16A from TIN Web Site
For the financial year 2011-12, it is mandatory for companies and banks to download Form 16A from TIN Website and issue only such downloaded TDS certificates to deductees. For others it is optional.
This facility has been activated in the NSDL web site
Step 1 : Login with your TAN
If you have not made online TAN registration, then it must be done immediately. You can login with TAN, login ID and password under Login->TAN Account menu
Step 2 : Request for Form 16A file
Click Form 16A file request menu. Prior to this keep eTDS statement for the desired quarter handy, as some verification questions will be asked for this request.
Select the Financial Year and Quarter for which Form 16A file is required
Two questions , one related to any one challan and another related to any 3 deductee details will have to be filled in.
You can make a request for either one PAN or all PANs
You may also download “PDF Converter” utility from the same menu.
Step 3 : Wait for file to arrive by email. This should arrive within 48 hours.
Prior to this keep the 12 digit online TAN registration number handy
The file attached to email will be a .zip file ,which will be password protected. And the password in this case is 12 digit TAN registration number.
After extracting the file you will get a .txt file
Step 4 : Covert txt file to PDF file
The java based utility can read the txt file and convert the same to Form 16A PDF format
Comments on Form 16A generated
Fast Facts tried out the whole process for its own Q4 data and converted the txt file to PDF. Some observations
- A unique TDS Certificate number is coming for each certificate
- One certificate is getting generated for one PAN covering all TDS sections
- CIT TDS name and address is automatically coming
- Address of the Deductee is automatically coming based on the PAN database with the department
- One additonal column Status which shows Booking status is also appearing against each line
Now TIN Website to provide Form 16A
CBDT has issued Circular 03/2011 on May 13, 2011 detailing new procedure of Issuance of TDS Certificates in Form No. 16A downloaded from TIN Website and option to authenticate the same by way of digital signature
|
FY 2010-11 |
FY 2011-12 |
|
| Download Form 16A from TIN Web Site | Optional | Mandatory for Companies and Banks. Optional for others |
| Digitally Sign Form 16A | Optional but only if downloaded from TIN Web site | Optional but only if downloaded from TIN Web site |
| Manually Issue TDS Certificate | All deductors can manually issue TDS Certificate | Companies and Banks cannot manually issue TDS Certificate |
TDS Certificates Form 16A for Financial Year 2011-12
- For the following categories of deductors, it is mandatory to download Form 16A from TIN Web Site and issue such downloaded certificates to deductees
- Companies
- Banks
- Co-operative society engaged in banking business
- For other deductors, it is optional to download Form 16A from TIN Web site
- Such downloaded TDS certificate will have a unique TDS Certificate Number
- This procedure is applicable for all deductions made on or after 01-04-2011
TDS Certificate Form 16A for Financial Year 2010-11
- Any deductor has option to download Form 16A from TIN Web site.
- It is not mandatory for any one
Digitally Signing Form 16A
- A deductor has option to digitally sign Form 16A .
- However this option is available only in respect of Form 16A downloaded from TIN Website.
- TDS Certificates not downloaded from TIN web site will have to be manually signed
Procedure and Format
- Director General of income-tax (Systems) shall specify the standards , procedure and format for issuing of TDS Certificates by way of downloading from TIN Web Site
FVU 3.2 : Key Changes
In quick succession , NSDL has released new FVU version 3.2 for FY 2010-11 and FVU 2.130 for prior years.
FVU version 3.1 was released on March 18,2011. Details can be viewed in our blog http://blog.ffcs.in/2011/03/21/new-validations-fvu-3-1/
Based on user feedback, the present FVU has been launched
The key changes vis-à-vis FVU 3.1 are described below
Rounding Off problem leading to T-FV-4278 Error
In our earlier blog Fast Facts Bulletin had mentioned how rounding off to nearest rupee was resulting in validation error T-4278. http://blog.ffcs.in/2011/04/27/fvu-3-1-tds-rounding-off-validation/
This problem was reported to NSDL and Income-tax department and now stands resolved in FVU 3.2
Reporting Transactions below threshold
Transaction below threshold limit must have : “Y” in the column “Reason for non deduction /lower deduction” , 0.00 as rate of Deduction, 0.00 as Amount Deducted, 0.00 as Amount Deposited
Deductor has option to report such transactions
- The new guidelines issued by Directorate of Income Tax – Systems state the words “..if deductor wishes to report ……”
- Hence it is clear that user has the option to report transaction below threshold limit
Deductor can adopt one of three approaches to show such transactions
n FVU 3.1 only one method of showing such transaction was given. Now there are three different ways such transactions can be shown. For ease of explanation,we will use the following abbreviations :
TBT : Transaction below threshold
TCT : Transaction crossing threshold
Approach 1
- Show TBT and TCT in the same quarter in which payment is made / amount is credited
Approach 2
- Show TBT in the quarter in which related TBC is shown and TBT to be shows with Rate 0 and Date of deduction blank
Approach 3
- Show TBT in the quarter in which related TBC is shown and TBT to be shows with Applicable Rate and Date of deduction as date of TBC
Example
Interest paid in Q1, Q2 and Q3. Threshold crossed in Q3
| Date of Payment | Amount Paid | Rate | Date of Deduction | Tds Amount | Flag | To be Shown in | Approach |
|
01/04/2010 |
1000 |
0 |
0 |
Y | Q1 |
Approach 1 |
|
|
01/07/2010 |
1000 |
0 |
0 |
Y | Q2 | ||
|
01/10/2010 |
4000 |
15 |
01/10/2010 |
600 |
Q3 | ||
|
01/04/2010 |
1000 |
0 |
0 |
Y | Q3 |
Approach 2 |
|
|
01/07/2010 |
1000 |
0 |
0 |
Y | Q3 | ||
|
01/10/2010 |
4000 |
15 |
01/10/2010 |
600 |
Q3 | ||
|
01/04/2010 |
1000 |
10 |
01/10/2010 |
100 |
Y | Q3 |
Approach 3 |
|
01/07/2010 |
1000 |
10 |
01/10/2010 |
100 |
Y | Q3 | |
|
01/10/2010 |
4000 |
10 |
01/10/2010 |
400 |
Q3 |
View point by Fast Facts
In our view, such important and far reaching changes must be announced for Q1 and not in Q4.
This will create confusion for deductors about treatment of TBT and TCT transaction already shown in Q1 , Q2 and Q3
Form 16 : Erroneous reference to Form 12BB
For tax deducted on salaries , the employer has to issue Form 16 to the employees. The form was modified vide Notification 41/2010 dated 31.05.2010
In this form there is a reference to Form 12BB
Gross Salary Rs.
(a) Salary as per provisions contained in sec.17(1) Rs.
(b) Value of perquisites u/s 17(2) (as per Form No.12BB, wherever applicable) Rs.
(c) Profits in lieu of salary under section 17(3) (as per Form No.12BB ,wherever applicable
However there is no Form 12BB notified. It certainly is a typo error and it should read Form 12BA
Reference may also be made to Circular 8/2010 : Section 192 of the Income-tax Act, 1961 – Deduction of tax at source – Salaries – Income-tax deduction from salaries during the financial year 2010-11
In this circular , detailed guidelines for compliance with TDS on salary are given for the FY 2010-11
Paragraph 4.6.5 of above circular clearly states that
“…..information related to nature and value of perquisite is to be provided by employer in Form No 12BA……..”
Hence deductors may treat this as type error and replace 12BB with 12BA.
Refund of Excess TDS Paid : Circular 2/2011
CIRCULAR NO. 2/2011 [F.NO. 385/25/2010-IT(B)], DATED 27-4-2011
If a deductor has deposited excess amount of TDS , the procedure for getting refund was given in Board Circular 285 dated 21-1-1980. Now CBDT has issued new circular in this respect.
- This Circular 2/2011 is issued in suppression of circular No 285 / 21-10-1980
- It covers TDS sections 192 to 194LA
- It does not cover TDS on non-resident payments i.e. section 192, 194E and 195 ( which are separately covered by circular No. 7/2007)
- It covers refunds for the period upto 31-03-2010 .
- Refunds for period thereafter will be covered under provision of section 200A which prescribes processing of TDS Statements
Excess to be refunded :
The excess payment to be refunded would be the difference between:
- the actual payment made by the deductor to the credit of the Central Government; and
- the tax deductible at source
Excess payment discovered during financial year
In case such excess payment is discovered by the deductor during the financial year concerned, the present system permits credit of the excess payment in the quarterly statement of TDS of the next quarter during the financial year.
Excess payment discovered after financial year
- In case, the detection of such excess amount is made beyond the financial year concerned, such claim can be made to the Assessing Officer (TDS) concerned.
- However no claim of refund can be made after two years from the end of financial year in which tax was deductible at source.
Safeguards to avoid double claims
To avoid double claim of TDS by the deductor as well as by the deductee, the following safeguards must be exercised by the Assessing Officer concerned:
The applicant deductor shall establish before the Assessing Officer that:
(i) it is a case of genuine error and that the error had occurred inadvertently;
(ii) that the TDS certificate for the refund amount requested has not been issued to the deductee(s); and
(iii) that the credit for the excess amount has not been claimed by the deductee(s) in the return of income or the deductee(s) undertakes not to claim such credit.
Prior approval of the Additional Commissioner is required for refund in excess of Rs. 1 Lakh
Prior approval of the Commissioner is required for refund inexcess of Rs. 10 Lakhs
After meeting any existing tax liability of the deductor, the balance amount may be refunded to the deductor.
FVU 3.1 : TDS Rounding Off Validation
FVU 3.1 was launched on March 18,2011 and is applicable for Q4 eTDS Statements for FY 2010-11 and FY 2011-12.
Many deductors are not able to create eTDS statement and are getting the following error:
T-FV-4278 Invalid tax deducted amount. Enter valid tax deducted amount.
New Validation for TDS Amount
The above error is because of a new validation introduced in FVU 3.1
Correct TDS Amount = Amount Paid * TDS Rate
TDS Amount Shown in Statement
Variance Amount = Correct TDS Amount – TDS shown in statement
Variance % = Variance Amount / Correct TDS Amount * 100
If the variance % is 10 or above – the above error is generated
Rounding Off problem leading to T-FV-4278 Error
A common practice among deductors is to round off TDS payable to nearest rupee. This practice has been followed for last several years. Now suddenly because of this new validation , such records are being flagged as erroneous.
Example : Amount Paid : Rs. 140 Rate 1% TDS Deducted Re 1.00
Correct TDS Amount = 140 * 1% = Rs 1.40
TDS Amount Shown in Statement = Re 1
Variance Amount = 1.40 – 1.00 = 0.40
Variance % = 0.40/ 1.40 * 100 = 28.57%
Solution
Income-tax department and NSDL have been apprised of this problem. A possible solution could be change in FVU to ignore the validation for rounding off cases.
Let us all wait for a new FVU version.
