Introduction:
Reconciliation of TDS reported by AINs with payments through OLTAS by State AGs is an important task for the field formation.

Existing Scheme:
In the Government Accounting System each deductor is associated with a specific Accounts Officer (AO) who processes the bills prepared by the deductor.

The Pay and Accounts Office (PAO)/District Treasury Office (DTO)/Cheque Drawing and Disbursing Office (CDDO) are required to file Form 24G as per Income-tax Department Notification no. 41/2010 dated May 31, 2010. In case of an office of the Government, where tax has been paid to the credit of Central Government without the production of a challan associated with deposit of the tax in a bank, the PAO / CDDO / DTO or an equivalent office (herein after called as AO in this document) government is required to file Form 24G.

A unique seven digit Accounts Office Identification Number (AIN) shall be allotted, to every AO. Every AO shall furnish one complete, correct and consolidated Form 24G every month having details of all type of deduction / collection viz. TDS-Salary / TDS-Non Salary / TDS-Non Salary Non Residents / TCS.

Existing CGA instructions

ARRANGEMENTS FOR CREDIT TO CENTRAL GOVERNMENT OF INCOME TAX DEDUCTED AT SOURCE (TDS) FROM THE SALARY AND OTHER BILLS OF STATE GOVERNMENTS.

Consequent upon departmentalisation of receipts accounts of Union Govt. (Civil), the income tax recoveries effected from the bills paid by the treasuries/State Government Pay and Accounts Officers/other State Government departmental offices rendering compiled accounts to the Accountants General shall be classified under the Minor head "TDS Suspense" below the Major head "8658 Suspense Accounts" in the State Section of accounts. The credit to this head will be accorded by transfer credit even at the time of recording pay order as per the provisions of Article 26 of Account Code Volume-II. These offices should also maintain details of credit to the suspense head as above under the various major, minor and detailed heads of account relating to deductions of income tax at source like "0020","0021", etc.

The Accountant General, will consolidate on a monthly basis for the State Circle as a whole the amounts shown under TDS Suspense by these authorities. A cheque for the total amount booked under TDS Suspense shall be sent by him, after the monthly accounts are closed, to the Zonal Accounts Officer concerned duly supported by a statement in duplicate showing the figures pertaining to each treasury/ PAO/ Departmental officer rendering compiled accounts etc. On receipt of the cheque and realising the same through the accredited bank, the Zonal Accounts Officer of the CBDT will straightaway classify the credits to the relevant major, minor and sub-heads of accounts on the basis of the source at which the deduction has been made as indicated by the Accountant General in the statement referred to above by keeping in view the guidelines prescribed in CGA's O.M. No. S. 11024/1/80/TA/2457 dated 24th June, 1980.

Issues for consideration
It is seen that there are following lacunae in the functioning of the scheme:

a) List of active AIN holders is less than total no of AINs allotted.

b) Amount reported by state Government AINs in form 24G is less/more than the amount reported by the State AGs as consolidated deduction during the year.

c) Due to such a reporting, inference is drawn that whether any TDS collection was left to be accounted for or there was any incorrect reporting in Form 24G.

d) It is also seen that there are substantial delays in deposit of TDS collections by AGs, some times more than months.

e) TDS claimed by deductees of State Government departments in their individual returns of income, is more than the figure reported by State AGs/Form 24G.

Standard Operating Procedure (SOP) defining the roles of different TDS Authorities in addressing the issue of GOLTAS reconciliation

(I) Role of Pr. CCIT(CCA)/CCIT(TDS):
(i) Interacting with Chief Secretary of State and Principal A.G. to highlight the issue
(ii) Taking up the issue of belated remittance of Government TDS
(iii)Suggesting follow-up action, if any, required with respect to the above
(iv) Discussing and obtain details of progress made in such cases from CsIT(TDS) under him.

(II) Role of CIT(TDS):
i) Co-ordinating with State Government finance department and Account Officers and AGs (A&E) to solve the issue
ii) Maintaining a master list of AIN holders in his jurisdiction and periodically remove inactive AINs
iii) Updating AIN-TIN mapping with the help of CPC(TDS)
iv) Removing inactive TANs/AINs based on information sent by CPC-TDS and on enquiries made by AO – TDS.
v) Monitoring compliance in filing of Form 24G by the PAO/Treasury Officers (the AIN holders).
vi) Sensitizing them towards dissemination of BIN to the Govt. deductors. The 24G Statements filed by the AIN holders should be utilized to issue notices to Government deductors to file their TDS statements in time.
vii) Monitoring timely receipt of TDS payments of State Government through Accountant General.
viii) Causing enquiries to be conducted in case of AINs not issuing BINs/Not filing statements/under reporting TDS made by them.
ix) Holding seminars with big Central Organizations to educate and familiarize them with the procedures for proper capturing of TDS data AIN-wise.
x) Ensuring that the State AGs send a report as prescribed in CGA’s OM No. S11024/1/80/TA/2457 dated 24.06.1988.
xi) While giving approval for the fresh AINs to be allotted, the CIT(TDS) should verify the justification for requirement of such AIN.
xii) Reporting the outcome/efforts made in the monthly D.O. letter.

(III) Role of Addl. CIT(TDS):
i. Liaisoning with NSDL for regularly updating the AIN registry and ensuring correct data entry in respect of AINs.
ii. Developing a liaison for new Offices/new DDOs may be requested to obtain AIN/TAN on a priority basis.

(IV) Role of AO – TDS:
i) Verifying the correctness of Form 24G and report the incorrect details to CPC and ensure correctness from deductors.
ii) In case of non-filers, ensuring compliance from assessee deductors.
iii) Conducting awareness programmes in case of Govt./semi-Govt. offices having five or more DDOs /PAOs.

(V) Role of CPC-TDS:
i. Running Back end queries and reports to identify inactive TANs/AINs and remove them from the data base in coordination with CITs(TDS).
ii. Updating AIN-TAN mapping frequently and intimate field formations.
iii. Running reports to identify cases where TDS reported by State AGs does not tally with that reported in form 24G.
iv. Identifying AINs/TANs responsible for this and intimate field formations.
v. Running Back end queries and reports to identify inactive TANs/AINs and remove them from the data base in coordination with CsIT(TDS) and generate and disseminate such reports periodically.
vi. Updating AIN-TAN mapping frequently and intimate field formations.
vii. Running reports to identify cases where TDS reported by State AGs does not tally with that reported in form 24G.
viii. Identifying AINs/TANs responsible for this and intimate field formations
ix. Identifying AINs not issuing BIN and communicate the same to AO – TDS and Addl. CIT(TDS).
x. Identifying the incorrect details filed in AIN directory and generate such reports periodically.
xi. Making accessible report about AINs /TAN in other CsIT(TDS) charges in the same state to all CsIT in that state, so that there may be better co-ordination