Form 61A – Statement of Specified Financial Transactions (SFT)

For keeping a watch on the high-value transactions done by the taxpayers, the Income Tax Act has framed a new concept to furnish a Statement of Financial Transactions or reportable account, previously also known as Annual Information Return (AIR).

Section 285BA of the Income-Tax Act requires specified reporting persons to furnish this statement. Rule 114E of the Income Tax Rules 1962, specifies that this statement must be furnished in Form No. 61A.

Which are the Specified Financial Transactions?

The specified financial transactions referred above are of the following kinds:

• Sale, purchase or exchange of goods, right, property, or interest in any property.
• Works contract.
• Providing services.
• Any investment made or expenditure incurred.
• Accepting any deposit or taking any loan.

It is important to note that CBDT can recommend different values with respect to different transactions for different persons by considering the nature of the transactions.

Due Date to File Form 61A

Statement of Financial Transactions needs to be furnished within 31st May of next year for every previous financial year where the transaction occurs.

A penalty under Section 271FA of Rs 500 per day shall be levied for the initial failure to file within the due date. The authorities would issue a notice to such an assessee, demanding the assessee to submit the form within 30 days from the issuance of such notice. 

In case such assessee continues to be the assessee in default by not answering to such notice, a penalty would be levied on the assessee that would amount to Rs 1000 per day of such default. This penalty would be calculated from the expiry of the period as stipulated in such notice.

Who is required to furnish Form 61A

• A banking company, Cooperative bank
• A non-banking financial company (NBFC)
• Any institution issuing credit card
• Any person covered under audit under section 44AB iof the Income Tax Act.
• Post offices
• A Nidhi referred to in section 406 of the Companies Act 2013
• A company issuing bonds or debentures
• A company issuing shares
• A mutual fund institution
• A company listed on the recognised stock exchange 
• A trustee of a mutual fund or such other person as authorised by the trustee
• Authorise dealer, offshore banking unit, money changer or any other person defined in FEMA
• Inspector general or sub-registrar appointed under Registration act, 1908

Transactions to be reported in Form 61A

Filing Nil Statement

There’s a dilemma many have that if an entity that hasn’t entered into any of Specified financial transactions in the financial year but falls into the reporting class of person as provided under the provisions of the Income Tax Act – Do they need to file a NIL Form 61A/Statement of financial transactions. 

There have been few circulars issued by the CDBT (Central Board of Direct Taxation) on the same which somewhat hasn’t solved the dilemma, however, experts in the field recommend that Nil Statement is not mandatory but to stay on the safer side an assessee could consider filing the STF (Statement of Financial Transactions) or Form 61A

Filing of Statement of Financial Transactions (SFT) Online

• Step 1: Register on the Reporting portal under My Account menu.
• Step 2: All statements uploaded to the Reporting Portal should be in the XML format consistent with the prescribed schema published by the Income Tax Department.
• Step 3: Once XML is generated, sign and encrypt the XML using the Submission utility and prepare a package to be uploaded.
• Step 4: Submit the statement on Reporting Portal. 
  Upon successful submission, an email with “Acknowledgment Number” will be sent to the registered email id.

Different Parts of Form 61A

Form 61A has two parts: 

• Part A which contains statement level information is common for all transaction types. 
• The report level information has to be reported in one of the following parts (depending on the transaction type): –
  •  Part B (Reporting of aggregated financial transactions by the person) 
  • Part C (Reporting of bank accounts) 
  • Part D (Reporting of immovable property transactions)

Rules of Aggregation

Threshold limit shall be applied on the aggregate of the following:

• All accounts of same nature
• All transactions of same nature
• In case of joint accounts, amount to each account holders is added
• Limit should be applied seperatley to deposits and withdrawals

Exceptions to above rules:

• Purchase and sale of immovable properties
• Cash payment for goods and services

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