Finance Technology & Automation

For Ind AS-compliant companies, revenue from SaaS subscriptions must be recognised under Ind AS 115 — Revenue from Contracts with Customers — by identifying the performance obligations in the contract, determining the transaction price, and recognising revenue only as those obligations are satisfied over the subscription period. For non-Ind AS companies, the applicable standard is Accounting Standard 9 (AS 9) — Revenue Recognition — issued by the ICAI, which requires recognition only when no significant uncertainty exists regarding the amount of consideration. Automated reconciliation tools must therefore map subscription billing cycles to deferred revenue (contract liability) accounts and release them on a straight-line basis unless a different pattern of transfer of control is demonstrated. GST collected on subscription invoices under Section 13(2) of the CGST Act 2017 is a point-of-issue liability and does not follow the deferred revenue treatment, creating a mismatch that reconciliation tools must specifically handle. A CA's sign-off on the revenue recognition policy embedded in the tool configuration is essential to ensure compliance.

Automation of TDS under the Income Tax Act 1961 requires the system to correctly apply the relevant TDS rate by nature of payment — for example, Section 194J for professional fees at 10%, Section 194C for contractor payments at 1% or 2%, and Section 195 for foreign remittances — and to deduct at the time of credit or payment, whichever is earlier, per Sec 200, IT Act 1961 (≡ §397, IT Act 2025) of the Income Tax Act 1961. Tax deducted must be deposited using Challan ITNS 281 by the 7th of the following month (or 30th April for deductions in March), failing which interest under Section 201(1A) accrues at 1.5% per month from the date of deduction to the date of deposit. Quarterly TDS returns in Form 24Q (salary), Form 26Q (non-salary domestic), and Form 27Q (non-resident payments) must be filed by the deadlines specified in Rule 31A of the Income Tax Rules 1962. A well-configured automation tool should generate exception reports for new vendors where PAN is not available, since TDS must be deducted at 20% under Section 206AA in such cases.

GSTR-2B is a static auto-drafted statement generated by the GST Network on the 14th of each month reflecting the Input Tax Credit (ITC) available to a recipient based on the outward supplies declared by its suppliers in GSTR-1. Under Rule 36(4) of the CGST Rules 2017 (as amended), a recipient can claim ITC only to the extent it appears in GSTR-2B; the earlier provisional claim of 5% additional ITC (over and above GSTR-2B) was withdrawn from January 1, 2022. Automated reconciliation tools must therefore match every purchase invoice in the books against GSTR-2B line by line, flag invoices not appearing in GSTR-2B as ineligible for ITC in the current month, and track them for subsequent months when the supplier files. Wrongful ITC claims are recoverable with 24% interest per annum under Section 50(3) of the CGST Act 2017, making accurate GSTR-2B reconciliation a legal imperative rather than merely a best practice.

The Reserve Bank of India's circular on Storage of Payment System Data dated April 6, 2018 requires all payment system operators to ensure that the entire data — end-to-end transaction details, payment data, and customer data — related to payment systems operated in India is stored only in India within a period of 6 months. For account aggregators and lending platforms, the RBI Master Directions on Non-Banking Financial Companies (Account Aggregator) Framework 2016 impose additional consent architecture requirements under Section 45I of the Reserve Bank of India Act 1934. The Digital Personal Data Protection Act 2023, once its Rules are notified, will impose further obligations on data fiduciaries handling sensitive financial data, including consent mechanisms, data minimisation, and breach reporting to the Data Protection Board within prescribed timelines. A CA advising a fintech must review the technology architecture against these requirements and include a specific representation in any due diligence report or board-level compliance certificate.

Under Section 209 of the Companies Act 1956 (now Section 128 of the Companies Act 2013), every company must maintain books of account that give a true and fair view of the state of affairs and explain its transactions, and such books must be preserved for 8 years. A management dashboard that draws data from the accounting system is not itself a book of account but must produce outputs that are traceable — drill-down from a dashboard number to an individual journal entry with date, narration, and voucher reference — to satisfy the auditor's demand for audit evidence under Standards on Auditing SA 500. For income tax purposes, where scrutiny assessments are conducted under Section 143(3) of the Income Tax Act 1961, the Assessing Officer may require print-outs of reports relied upon by management; these must reconcile exactly to the books without manual intervention. Dashboards should therefore be read-only aggregations from the ERP or accounting software, with a complete audit trail log maintained under Guidance Note on Audit of Internal Controls issued by the ICAI.