1. The e-PR 7 Utility is only allowing to save draft in XML format. It is not allowing to save the 3CD in either PDF format or any other format before the same is uploaded by the Tax Auditor. As such the Tax Auditor is not in a position to check possible inconsistency/ error. It is some time not possible to verify the 3CD Statement by simply scrolling down the form since some data/ information of some of the fields disappear or is not in active view as explained somewhere herein. Though vide item 9 of the General Instructions the Department has advised to verify the Form before its submission but it has not made any such arrangement to save the same and verify. The said form can only be saved by the assessee before approving or rejecting the same. Facility be provided to the Tax Auditor to save the data before submission to avoid possible errors and ward off the repetitive process of uploading and re-upload on coming to know any data input error after the same is saved by the assessee.
2. The software has some inherent error to the extent that after a Draft saved file is reopened at least 10 fields asking for ‘yes” or “no” has to be re-entered as many number of times one reopens the draft saved data xml file. These fields are clause nos 7(b), 8(b),9(a),10, 11(d), 12 (b), 21(note), 22(a), 22 and 23.
3. The display in clause no 28 (quantitative details) also shows only one row on reopening of the Draft leading to misbelieve that whether data in only one row was entered?. The other rows gets themselves hide in the software resulting into unnecessary embarrassment to the person feeding the data. The information, however, is intact in the XML file.
4. Up till now, the site is allowing upload of 3CD by the Tax Auditor multiple times for the same assessee for the same Assessment year without flashing a warning that the same has already been uploaded by the Tax Auditor. (However the site do not allow the Tax Auditor to upload the same xml file which has been rejected by the assessee flashing a reason that the DSC of the Tax Auditor is invalid.)
5. Vide item 5(a) of General Instructions the size of attachment permitted is 50 MB whereas in the utility Form to be uploaded the size along with attachment has been restricted to 20MB only. The anomaly needs to be clarified.
I have e-mailed to our dtc@icai.in to pursue such issues with concerned authorities for remedial action.