Wednesday 11 December 2013

Income Tax Refunds in India: Improvement in Systems and Processes


                     
By- Ajay S Singh[1], ICAS
1.1.    Direct taxes in India are administered by Department of Revenue, Ministry of Finance, through Central Board of Direct Taxes (CBDT), whereas Indirect Tax is handled by Central Board of Excise and Customs. Refunds of direct taxes have been studied and recommendations presented in this paper are limited to direct taxes collected by CBDT through its field offices. Taxes are collected through a network of more than 13000 bank branches of 32 Banks of India. Accounting of tax received and expenditure incurred in the process of administering tax is done by Principle Chief Controller of Accounts, Department of Revenue. Refunds are, however processed and paid by CBDT and only the amounts paid are captured in the accounts without any robust mechanism of reconciliation with payments due, authorized and paid by CBDT. There is need to carry out reforms in the administration of taxation in general but process of refunds in particular. In this paper, current systems of refunds in India, global experiences in taxation and way forward to make refunds more user friendly and systematic have been dealt.

1.2.    Key activities in the administration of taxation systems are the effective collection of taxes and management of tax refunds and credits. Tax administrators face an ongoing challenge in meeting the taxpayers‘expectations of empathy in service delivery and ensuring prevention of fraudulent and erroneous refund claims. As a result of the global financial crisis (GFC) in 2008 and 2009, the challenge of tax administration grew considerably. The United Nations International Conference on Financing for Development held in Monterrey, Mexico in 2002 gave birth to the Monterrey Consensus[2]. Since its adoption on 22 March 2002, it has become the major reference point for international cooperation in the development field. The first two areas of financing for development found out by the Monterrey consensus were: “Mobilizing domestic and international financial resources for development”. Tax authorities were therefore solicited to cope with these two missions and to enter into an effective cooperation between them. The heads and deputy heads of tax administrations from 35 countries met in Seoul, Korea on 14-15 September 2006 and issued the Seoul Declaration[3]. The Declaration insisted on the necessity of continuous adaptation and effective reform for the tax administrations. Reforms are aimed at improving tax administration which includes improving processing and release of refunds also.

1.3.    India has been striving to simplify taxation systems. For filing returns, forms have been simplified and now taxpayers are given the facility of filing their returns through an on-line system. Further simplification in taxation is at its advance stage where Direct Tax Code[4] (DTC) has been devised and modalities are being worked out for its implementation. In the process of simplification of tax administration, refunds are also getting a lot of focus. As of now returns are filed electronically as well as in paper mode. Whether returns are filed electronically or through paper mode, tax credits are invariably captured and stored on a portal which is available for viewing of taxpayers. Despite tax credit being available on a portal, there are gaps in authentication and validation of credits; which has forced the processing of refunds to be handled in rudimentary manner. For a country like India, the number and value of refund claims being made by taxpayers are so huge that this task of managing refund takes a different dimension.

1.4.    Currently there are more than 35 million assessees out of which about 35% i.e. 13 million are getting refunds of direct taxes. The total refunds during F.Y. 2011-12 amounted to Rs.935.70 billion[5], of which only Rs.146.70 billion has been through e-mode under ‘e-refund’ through Refund Banker Scheme. E-refund is done only in cases where assessee opts for it and refund amount is not more than Rs.50,000/. Currently e-refunds and paper refunds other than cases dealt in scrutiny and large tax payers are handled through refund banker scheme. Paper Refund is not only causing delay but it is also not environment friendly. There are grievances of refunds not getting released without seeking favour or released and sent to old address which tax payer may have changed in the intervening period. There are also cases of refunds being siphoned out by unauthorized persons due to lack of validation mechanism in the refund process. It is, hence felt that efforts be made to increase e-refunds in a phased manner, eliminating paper refunds completely where many controls may be effected.

2.1.    The legislative and policy framework that revenue bodies operate within India is very robust but often blamed of being rigid and too bureaucratic. Methods, techniques and approaches employed to improve detection and treatment of fraudulent and otherwise non-compliant refund claims are a major focus of attention. The sensitivity of these topics poses a barrier to the free exchange of the detail of the approaches which would otherwise enable revenue bodies to learn more rapidly from others ‘experiences. In India, there is no established and scientific mechanism to detect frauds in refunds. Despite huge data being available with CBDT, only recently some scattered attempts have been made to analyse data and find out cases of apparent frauds in refunds. Most of the frauds have been unearthed due to information provided by intelligence or outside sources. There is a lot of potential in data mining and data analysis for validation and ascertainment of refunds.
2.2.    In USA, the mechanism to identify frauds has been established in a manner that a lot of fraud cases are identified and fraudulent payments are stopped. However, number of cases and increase in them indicates that problem is severe and there is a need to have some deterrent force to discourage fraudsters to try out seeking refunds. USA follows an elaborate post-refund risk management. They follow a metric called the no-change rate where the numerator is the number of audits that result in no change to what the taxpayer originally reported and the denominator being the total number of audits. Audit results are tracked on a monthly basis, and if the no-change rate increases, Headquarters staff determines the root causes (training, selections, etc) of the lower rate of audit results. By following this method a large number of cases of fraud have been identified and more importantly, the payments of such refunds have been stopped. For filing season 2009 the IRS identified 280,216 fraudulent returns with false withholding and deleted 192,104 of them. Corresponding refunding identified was $1,909,762,784. Refunds deleted were $1,437,911,310. It is evident from the table that there is about 8 fold increase in identification of fraudulent returns whereas success rate in stopping the payment against them has further increased to more than 9 fold. In money terms, the cases identified have grown by 1002% over this period from 2006 to 2009 where as payment stopped in the corresponding period has increased by 1234%.

Trends in the rate of detection over recent years

Fraudulent returns and refunds (with false withholding) identified and stopped
(Processing Years 2006 -2009)

Processing Year
 Number of Fraudulent Refund Returns Identified
Number of Fraudulent Refund Returns Stopped
Amount of Fraudulent Refunds Identified ($)
Amount of Fraudulent Refunds Stopped ($)
2006
                             52,255
                        35,523
                271,180,566
                188,715,519
2007
                           240,406
                      189,915
             1,467,762,110
             1,203,795,853
2008
                           380,656
                      306,128
             1,959,992,377
             1,683,912,973
2009
                           457,369
                      369,257
             2,988,945,590
             2,517,094,116
2006-09
                       1,130,686
                      900,823
             6,687,880,643
             5,593,518,461

Source: Draft TIGTA analysis of IRS data, verified by CI except for 2006 (from Draft TIGTA report: Interim Results (March 24, 2010) of the 2010 Filing Season).

2.3.    Government of India also faces several challenges in the field of refunds. Even though data on tax credits are available and returns are also available with CBDT, in many cases refunds are processed very late and it is alleged to lack transparency. There are cases where tax credits do not match with claimed credit of the assessee, primarily due to poor tax administration and lack of mechanism to ensure that credits are reflected correctly against the bonafied taxpayers. There is a need to establish a mechanism to capture Tax Deducted at Source (TDS) and tax credit data and ensure that assessee/deductor and deductee data are reconciled without any delay. Further it must be ensured that deductors are not allowed to play with the tax credits of deductees. One activity which may be done immediately and it may lead to huge customer satisfaction is ensuring transfer of refunds to the bank account of assesses. In the process of refunds, there is a need to ensure release of refunds in a defined and short time frame and credited to the bank account of the beneficiary. This may be done by migrating from paper refunds to electronic refunds. This process also has many challenges.

2.4.    As of now all assessees have the option to file tax returns either electronically or in paper form. Individuals and non-corporates with the taxable income of upto Rs. 100,000 in a year are free to exercise this choice. Similarly corporates are also required to file returns electronically, if the taxable income is more than Rs.10 million in a year. However, while filing returns assessee has the option to give bank details and ask for refunds to be released electronically to the bank account of the assessee. Alternatively, assessee may opt for payment of refunds through cheque/paper instruments. In these cases, it is not mandatory to provide bank details, hence e-refund is not possible in these cases. Even in the cases where bank details are available, government is apprehensive about accuracy and validity of bank details hence only the refunds of less than Rs. 50,000/- each is handled electronically using NECS mode of fund transfer. This choice of a smaller ceiling for refunds is driven by risk perception of the government, where it is felt that risk involved in e-refund is more hence for amount upto Rs.50,000/-, this risk may be taken. Further, there is a challenge of handling huge data of refunds, its bank-wise segregation and transmission in a secured mode. Refunds are also not processed electronically for all cases where Tax credits as per Form 26AS, a form containing details of tax credits for all tax payers, do not match with the amount of tax credits claimed by the assessees.  This tax credit mis-match is a serious issue and government has to process refunds in all such cases after manual scrutiny and processing of returns. Further, refunds to the assessees handled by Large Taxpayer Units and cases taken up for scrutiny by the government are also done through paper mode. Income Tax Returns are filed by the assessees either electronically or manually. Corporate and individual assessees with annual taxable income of more than Rs.1 million are required to file their income tax returns electronically. Corporates and many individuals file their returns using digital signatures. Electronic returns filed by assesses either using digital signature or otherwise contain the relevant data like MICR code, bank account number etc. required to process refunds. Since bank details in the returns submitted using digital signature are authenticated by the assessees, refunds to the given account numbers can be done without any difficulty. Though possibility of giving wrong account number in such cases may not be ruled out, it is the responsibility of asseesse to ensure accuracy of data. However, In the case of electronic returns filed without digital signatures ascertaining validity of data still poses a challenge. Possibility of frauds cannot be ruled out in these cases, since in these cases returns are filed electronically, but in an unsecured mode, returns can be filed by unauthorized persons to defraud the system.

2.5.    In the paper mode of returns filed by assessees, vital details of the taxpayers are keyed in by the officials or authorized representatives of CBDT. Data entry errors can be either bonafide or malafide where such large volume of data is handled in a short span of time. Huge amount of tax is collected by the Large Taxpayer Units (LTUs). LTUs deal with large taxpayer assesses who are also entitled for huge refunds. Their refunds are processed manually after detailed scrutiny by the specially created office (LTUs) to handle these assessees. However, refunds of LTUs may be switched over to electronic mode without any difficulty. Cases of assessment referred for scrutiny are also handled manually after the detailed scrutiny by the respective ITOs. After scrutiny, these cases may also be handled through e-refund mode.

2.6.    Once the returns are filed, there is time available till the refund is made, to conduct post issue risk assessment activities and do all possible activities in anticipation of the next filing period. Where the filing, or claim, cycles are shorter, it imposes further constraints on the capacity of revenue bodies to identify and respond to changes to maintain contemporary refund settings between cycles. Similarly, reductions in the service period resulting from improvements in service delivery, including electronic filing and processing, could further increase the pressure on CBDT’s pre-issue refund risk capabilities. In all cases of refunds, core issue of concern is validation of bank account of the tax assessees with PAN number and name of the taxpayer to ensure that money is credited into the accounts of the intended persons. Presently as per Reserve Bank of India instructions, the only validation, third party bank conducts is to ensure that the account no. in the pay instruction (either cheque or e-mode) pertains to their bank/ branch. While clearing cheque or receiving payment through e-mode receiving bank does not look at any other detail associated with the bank account number. Thus the validation of accounts with PAN number has to be done separately and before sending the payment instruction. Hence, challenge is to validate a large number of bank account numbers with their PAN numbers.

3.1.    Taxpayers with a bona fide claim to a refund of overpaid tax have a legitimate expectation that their refund shall come to them in a timely manner. The definition and perception of what constitutes a timely manner is likely to be influenced by a range of factors (e.g. the strength of a CBDT’s capability to quickly validate refund claims and obligations to pay interest on delayed refunds). Tax authorities commit to respecting a set of taxpayers ‘rights that are either stated in law and/or set out in administrative materials. These taxpayer rights are often accompanied by a set of service delivery standards that identify targeted timeframes for the completion of specified services.

3.2.    It has been observed that different types of taxpayers have different levels of service expectations. There are huge amount of tax paid by a small number of tax payers. In India, in the year 2012-13 only 213 top taxpayers paid more than 6.5% of the total direct tax collected in India. About 90% income taxpayers have their income in the range of upto Rs.500,000 p.a. and their tax payment is only about 10% of income tax collected in the country. There are huge numbers of taxpayers who pay very less amount of tax hence they are only marginal taxpayer. Thus only 10% taxpayers[6] contribute to more than 90% income tax collected in India.

3.3.    The table below indicates the number of taxpayers paying more than 50% of the total direct tax. Such tax payers need to be treated differently than the taxpayers who are large in number but their contribution towards the tax kitty is very small. From this table it is clear that a lot of taxpayers are only marginal taxpayers and their refund amounts are very small. Such taxpayers have potential of giving wide publicity about their experience of the refund process. Thus, they act as catalyst in encouraging or discouraging the other marginal taxpayers to come to the fold and start paying tax. Such taxpayers shall, therefore be treated differently. Since the refund amounts are very small, it shall be handled through automated system and random validation checks about the authenticity of the claims of the taxpayers. In these cases, possibility of fraud may not be ruled out, but monetary impacts of frauds are likely to be insignificant. Out of 9.7 million cases of refunds 9.1 million taxpayers have got refunds of less than Rs.100,000. Such large number of cases is only amounting to INRs 105 billion which is only 11% of total refunds. Majority of these taxpayers are getting refunds after due verification of credits available in their accounts. If the bank account validation is also carried out, then such refunds would have very rare possibility of going to wrong person. Thus a huge chunk of taxpayers would get their refunds very quickly and they would act as ambassadors of Government of India, advocating about the efficiency of tax administration in India.
Concentration of Domestic Tax Collection in Selected Countries[7]
Largest tax payers at national level
Country
Number
Percent of Total Taxpayers
% of collection
Peru
1,600
0.14
58
Argentina
2,450
0.25
51
Brazil
30,000
0.33
92
Colombia
5,922
0.41
65
Angola
250
0.44
80
Hungary
300
0.5
50
Nicaragua
400
0.67
75
Bolivia
1,350
1.35
66
Paraguay
1,000
1.7
60
El Salvador
1,005
1.68
75
France
52,000
2
50
Sri Lanka
2,024
2.02
92
Mali
53
4.8
60
Congo
50
5
65
Gabon
350
5.8
91
Uruguay
11,000
9
83


3.4.    In the case of Large Taxpayers Units (LTUs), a more personalized approach needs to be followed. Taxpayer must be provided best possible services to let him feel good about his contribution to economy of the country. Single window clearance of all tax related matters shall be dealt by a specialized set of office. Such office shall take care of all taxation related matters of such units.

4.1.    There are several risks associated with the process of refunds in the country. These risks are changing with the advent of technology and globalization of economy. Current and emerging risks in the field may be categorized under the broad heads having bearing on clients, transaction, service and organization. OECD in its report on Tax Payments has tabulated these risks in the following manner:


Sources of current and emerging repayment risks[8]

Current risks
Emerging risks
Client Risks
Ø  Identity fraud – fictitious or stolen identities.
Ø  Specific high risk industries.
Ø  Specific high risk occupations.
Ø  Regional location.
Ø  Distinct population group.

Client Risks
Ø  Foreign nationals or new citizens.
Ø  Identity fraud (especially using new technological medium), phishing and pharming.
Ø  Cash flow problems for taxpayers due to economic climate, especially where refund is a repayment in a preliminary/provisional refund system.
Ø  New businesses.
Ø  Organised criminal involvement.

Transaction Risks
Ø  Claims where 3rd party data is unavailable.
Ø  Hidden controlling or influencing 3rd party.
Ø  Collusion between credit provider and claimant.

Transaction Risks
Ø  On-line filing and associated weaknesses (e.g. authentication).
Ø  Low value-high volume fraud.
Ø  Fictitious Credit fraud.

Service Risks
Ø  Weakness in return filing channels, notably on-line filing.
Ø  Technology – complexity and provides opportunities for misuse/fraud.

Service Risks  
Ø  Out of country fraud attacks.

Organisation Risks
Ø  Legal complexity.
Ø  Friction between service and compliance outcomes.
Ø  Resourcing imbalances across service and compliance work.

Organisation Risk
Ø  Maintaining adequate resourcing.
Ø  Revenue or refund targets – pressure to restrict refund losses through compliance crack-downs.


4.2.    Risks associated with clients/taxpayers may be significantly mitigated by establishing a system of maintaining identity and validation data of taxpayers and put a mechanism in place to run through the data to prevent frauds in manipulation of identities of taxpayers. Other frauds may be dealt and shall be dealt by extensive research of the risks but identity frauds may be mitigated with minimum efforts. These frauds have huge monetary impact, thus its implementation is advisable. First step to eliminate this risk is to establish a process of transferring credits to the taxpayers using electronic refunds to the duly validated bank accounts.
4.3.    Before migrating to e-refunds, it needs to be seen whether it is possible to do so with the available taxpayer information in the returns filed by the tax payer or additional information may be required to be collected. If 100% e-refund is possible using the available information then same may be facilitated immediately. It is noticed that in the IT return forms, taxpayers are given the choice of getting their refunds electronically transferred to their accounts or through cheque. However, currently refunds are made through electronic mode to the asseessees who have opted for e-refund and their refund amount is not more than Rs.50,000/-. All taxpayers opting for transfer of refunds to their accounts may be easily covered under e-refunds without any delay and ceiling of refund amount.
Use of electronic filing for Personal Income Tax[9]
COUNTRY
Year begun
Rate of e-filing
% move in e-filing 2004/2008
e-filing target & year
2008
2003/4
Australia
1990
88
80
8
95(2009)
Canada
1992
54
48
6
+2%/year
France
2001
19
4
15
24(2009)
Ireland
2001
75
40


Korea
2004
81
35


The Netherlands
1996
85
80
5
100
Spain
1999
41
9
32
43(2009)
Turkey
2005
99
0
99
100
United Kingdom
2000
66
13
53
75(2010)
USA
1986
58
40
18
80

4.5.    In India, electronic filing has taken a quantum leap. During 2010-11, 76% returns of direct taxes were filed electronically. All corporates are now required to file their returns through electronic mode. During 2011-12 total 16.43 million taxpayers filed their returns electronically which increased to 21.48 million in the year 2012-13. By 31st Aug 2013 it has already touched 14.12 million which is more than 50% of the electronic returns filed during the corresponding period in 2011-12[10].   During last five years from 2007-08 to 2011-12, there has been a growth of about 900% electronic filing of returns. Against 2.17 million taxpayers in 2007-08 who have opted for electronic filing of returns, 21.49 million taxpayers who did electronic filing in 2008. This growth has to be enhanced further to achieve 100% e-filing. Till this year, electronic filing has been made mandatory for corporate taxpayers and High Networth Individuals. However, approach of government has been by and large persuasive to make taxpayers comfortable with technology and its usage.
Table: e-Filing status of collection of Direct taxes in India[11]
Financial Year
2007-08
2008-09
2009-10
2010-11
2011-12
2012-13*
No. of e-returns
2,169,367
4,830,122
5,073,977
16,433,684
21,486,807
14,119,365

4.6.    Electronic filing of tax and returns would reduce the manual intervention in tax administration process thus reduces the possibility of errors/mistakes happening in the data management of tax. It will greatly improve the refund process also. In manual returns, relevant data from the returns is captured manually at centres of CBDT. There are possibilities of errors creeping in while entering the data in CBDT’s systems. During 01/04/2008 to 31/03/2010, out of the nearly 1.10 lakh returned refund records of ECS/NECS, 91 thousand (82%) records attributed to “account description incorrect/invalid MICR code/invalid NECS MICR code”. Similarly during 01/04/2008 to 31/03/2010, out of the 177,000 records of paper-based instruments returned nearly 158,000 (89%) records attributed to “house locked/no such address/party shifted” reasons. Such returned refunds (electronic as well as paper based) are a miniscule percentage of total refunds of about 13 millions. Even in the electronic data entry systems (On-line), errors by the individuals are possible. The taxpayers frequently make mistakes in filling details at the time of filing returns. The mistakes may also be attributable to non-implementation of appropriate validations to check the PAN number and MICR code vis-à-vis bank account number in the software used to file returns .Thus the possibility of errors may be minimized at the data entry stage itself.
4.7.    At present it is not mandatory to file electronic returns. Further, currently bank details are mandatory only if taxpayers opt to receive refund through e-mode. In such cases, beneficiary account number and MICR code is provided in the return filed by the tax payer. Using MICR code e-refund is done using NECS method of transfer of funds. IFSC is used for electronic payment applications like Real Time Gross Settlement (RTGS), National Electronic Funds Transfer (NEFT) and Centralized Funds Management System (CFMS) developed by Reserve Bank of India (RBI).   The Code has eleven characters “Alpha Numeric” in nature. First four characters represent bank, fifth character is default “0”- left for future use and last six characters represent branch. Through this code, bank and branch may be captured and settlement would be smoother than ECS. Further IFSC code has wider reach than MICR and all bank branches are covered under this coding. Settlement of funds through ECS takes longer time and controls are also not very effective, therefore payments through NEFT shall be encouraged.
4.8.    Assessment of risks in electronic transfer of funds: Assessees who file their returns using digital signature, provide the bank details and PAN number which is used by the department through a secured mode without any manual intervention. In such cases bank details are authenticated by the tax payer. In other cases, bank account details are either captured through manual intervention or collated in unsecured mode.

5.1.    As a tax reform process, a beginning may be made by Government of India to migrate from paper refunds to 100% e-refund. In the cases where bank details of tax payers are available, bank account number, PAN no. and name of assessee shall be validated and refunds issued electronically. During 2010-11, there were 21.9 million taxpayers out of which 14.6 million have provided their bank accounts[12]. About 1 million taxpayers filed their returns using digital signature, hence their accounts don’t need to be validated. Further, there are more than 1.5 millions taxpayers who have got their refunds in the same bank account during last two years, which indicates that account number is correct and refund is going to the intended beneficiary. The cases of returns where bank details are not provided, it is essential to get the bank details from the tax payers. Therefore, it is necessary to make it mandatory to provide bank accounts and bank details in the returns. In the IT Returns, option of seeking return through cheque or draft shall be amended to make it mandatory to write the account no. and IFSC code of the bank. Refund cheque shall be issued in favour of taxpayer alongwith account no. written in front of the name. Further a rider may be added that, government reserves the right to refund the due amount using electronic refund method even though option has not been exercised by the taxpayer.
5.2.    Before attempting to migrate to 100% e-refund, a campaign needs to be launched to encourage tax payers to file their returns of direct taxes through on-line mode. This would eliminate the errors relating to PAN/TAN in the data uploaded by them and further reduce the problems of paper work to some extent. Mechanism may be devised to offer incentives for e-filing e.g. electronic refunds shall be processed before the manual refunds. Since the reform process involves huge number of taxpayers, it would be appropriate to follow an approach where implementation of reforms is done in a phased manner. In the first phase individual and non-corporate assessees who have filed their tax returns using electronic mode, with or without digital signature or paper returns but opted for e-refunds and provided the bank details shall be covered. It shall include all assessees who have provided bank details in their returns and got the refunds in the past two-three years in the same bank account. These assessees would get their refunds through electronic mode are paid refunds only when their tax credits available in Form 26AS matches with the details given in the returns filed. Further, the corporate taxpayers who have filed electronic returns using digital signature shall also be covered under e-refund. In all these cases, e-refund may be done without any monetary ceiling on refunds.
5.3.    For the cases where bank details of assessees are available but refunds are not processed in first phase, refunds can be processed in this phase. Account and Pan number validation may be exhaustively done and e-refund may be done for all validated cases. This shall include corporates and those who have filed returns electronically. Assesses who have not opted for e-refund to their bank account shall be dealt subsequently.

6.   Conclusion
6.1.    Refund initiatives have to necessarily have an integrated approach to the expectations of service delivery levels and mitigation of refund fraud risk. Any effort without a judicious balanced approach may lead to either increased grievances or huge loss to the exchequer. Management of risks associated with taxpayers’ registration and ascertaining their identity before release of refunds are areas of significant importance in the mitigation of refund fraud risk. This includes an emphasis on the ability to discover relationships between different sets of data pertaining to assesses. Improvement and enhancement of the process of identification and treatment of fraudulent, or non-compliant, refund claims involve developing sound structured database and analysis of data-sets from wide range of risk perspectives. Timely and reliable access to banking data and its validation with tax data (PAN no./ TAN no. etc.) would enable government to enhance tax return preparation and refund services. Further, providing validation at the time of filing returns improve the accuracy of filing and associated refund claims.

6.2.    Indian tax administration deals with refunds in a very unique and abnormal manner. It is only system in India where Consolidated Fund of India is allowed to be operated by a bank directly while releasing refund payments. Further, it is a system where government releases the payments and no mechanism is put in place to ensure that payments are reconciled with accounts and revenue collected. With computerization, massive data of tax collection and refunds may now be analyzed scientifically and reconciliation be carried out in an effective manner.





[1] Ajay S Singh, ICAS 1994 batch is Controller of Accounts in Central Board of Direct Taxes, Ministry of Finance, Government of India, views expressed are personal.
[2] See http://www.un.org/esa/ffd/monterrey/MonterreyConsensus.pdf
[3] See http://www.oecd.org/dataoecd/0/14/37463807.pdf
[5] Accounts at a Glance 2011-12, o/o Pr. Chief Controller of Accounts, CBDT
[7] Source dos Santos (1994)
[8]  Tax Repayments: Maintaining the Balance Between Refund Service Delivery, Compliance and Integrity, May 2011 report of Organisation for Economic Co-operation and Development.
[9]  Source: Respondent survey; OECD Comparative Information Series (2008); Netherlands Ministry of Finance and United Kingdom HMRC website :
[11] --ibid--
[12] Internal documents of o/o PrCCA, CBDT, Ministry of Finance, Government of India.                                                                   

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