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Full notification dt 30th December 2020 for extensions by CBDT

Extension of Time limit

1. In view of the challenges faced by taxpayer in meeting the statutory and regulatory compliances due to outbreak of covid-19. the Government has brought the Taxation and other Laws (Relaxation of central provisions) ordinance 2020 (“the ordinance”) on 31st March 2020 which, interalia, extends various time limits. The ordinance has since been replaced by the Taxation and other Laws (Relaxation and Amendment of Central Provisions) Act.

2) The Government has issued a notification on 24th June 2020 under the Ordinance which interlia, extended the due date of all income tax returns for FY 2019-20 (AY 2020-21) to 30th November 2020. Hence the returns of income which were required to be filed by 31st July 2020 and 31st October 2020 were required to be filed by 30th November 2020 . Consequently the due date of furnishing various audit reports including tax audit reports under the income tax act 1961 was extended to 31st October 2020

3) In order to provide more time to taxpayers for furnishing Income Tax Returns, the due date was further extended vide notification No 88/2020/F and 370142/35/2020-TPL Dated 29th October 2020

(A) The due date for furnishing of Income Tax Return for the taxpayers (including their partners) who are required to get their accounts audited (for whom the due date (ie before the said extension) as per the Act was 31st October,2020 was extended to 31st January, 2021

(B) The due date for furnishing Income Tax Return for the taxpayer who are required to furnish return in respect of International / Specified Domestic Transactions (for whom the due date (ie before the said extension) as per Act was 30th November 2020 was extended to 31st January 2021

(C) The due date for furnishing of Income Tax Returns for the other taxpayer (for whom the due date (ie before the said extension) as per Act was 31st July 2020 was extended to 31st December 2020

(D) Consequently the date of furnishing of various audit reports under the Act including Tax Audit Report and report in respect of International / Specified Domestic Transaction was also extended to 31st December 2020.

4) Considering the problems faced by the the taxpayers, it has been decided to provide further time to the taxpayer for furnishing of Income Tax return, tax audit report, declaration under Vivad Se Vishwas Scheme. Further, in order to provide more time to taxpayers to comply under various ongoing proceedings, the date of completion of proceeding under the Direct Tax & Benami Act have also been extended. These extensions are as under:

(a) The due date for furnishing of Income Tax Return for AY 2020-21 for the taxpayers (including their partners) who are required to get their accounts audited under and companies (for whom due date, as per the provisions of Section 139(1) of Income Tax Act, 1961 was 31st October, 2020 and which was extended to 30th November 2020 and then to 31st January 2021) has been further extended to 15th February 2021

(b) The due date of furnishing of Income Tax Returns for the AY 2020-21 for the taxpayers who are required to furnish report in respect of international / specified domestic transactions (for whom the due date as per provisions of Section 139(1) of the Income Tax Act, was 30th November 2020 and which was extended to 31st January 2021) has been further extended to 15th February 2021

(c) The due date of Income Tax Returns for Income Tax Return for AY 2020-21 for other taxpayers (for whom due date, as per the provisions of Section 139(1) of Income Tax Act, 1961 was 31st July, 2020 and which was extended to 30th November 2020 and then to 31st December 2021) has been further extended to 10th January 2021.

(d) The due date of furnishing various audit report under the Act including Tax Audit Report and report in respect of International / Specified Domestic Transaction for AY 2020-21 has been further extended to 15th January 2021.

(e) The last date for making a declaration under Vivad se Vishwas scheme has been extended to 31st January 2021 from 31st December, 2020.

(f) The date of passing orders under Vivad se Vishwas scheme which was required to be passed on 30th January 2021 has been extended to 31st January 2021.

(g) The date of passing of order or issuance of notice by the authorities under the Direct Taxes and Benami Acts which are required to be passed / issued / made by 30st March 2021 has also been extended to 31st March 2021.

5) Further, in order to provide relief for the third time to small and middle class taxpayers in the matter of self-assessment tax, the due date for payment of self-assessment tax date is hereby again being extended. Accordingly, the due date of self-assessment tax for taxpayers whose self-assessment tax liability is upto to Rs 1 Lakh has been extended to 15th February 2021 for the taxpayer mentioned in Para 4(a) and 4(b) and to 10th January 2021 for the taxpayer mentioned in para 4(c)

GST Annual Return

6) The Government has also extended the due date of furnishing annual return under section 44 of the Central Goods and Services Act, 2017 for the financial year 2019-20 from 31st December 2020 to 28th February 2021

7) Necessary notification in this regard will be issued in due course.

Extension request sent by various associations of CA, CS, CMA, Lawyer & Tax Professional

Various associations of tax consultants all over India is seeking extension of due date for filing Income Tax Return (ITR), Tax Audit Report, Transfer Pricing Audit report for the financial year 2019-20 / AY 2020-21.  Extension of due date for filing ITR & TP/Tax Audit report for AY 2020-21.

Request for extension of various due dates under Income-tax Act, 1961 for AY 2020- 21 and for filing the Annual Reconciliation Statement (GSTR9C) along with the annual return (GSTR9) for financial years 2018-2019 & 2019-2020

We wish to bring to your kind notice the following problems being faced by taxpayers/tax professionals due to the ongoing COVID19 pandemic and the resultant need to further extend the various due dates under the Income-tax Act, 1961 for AY 2020-21 as well as under the Goods and Services Tax Act for F.Y. 2018-19 & 2019-20.

As you are kindly aware that the effects of COVID19 pandemic is not yet over and is affecting all spheres of life even now. Taxpayers are equally affected. More recently, some metros like Delhi are seeing surge in Covid positive cases and there is a talk of a third wave. Similarly, in metros like Mumbai, the life line for millions of people i.e. the local trains are not yet activated for the common man. Most people are scared to travel by the other modes of public transport for fear of getting infected. The number of COVID positive cases continues to be high. This has forced many of the States to fix working hours and also week end lock downs, night curfews, restrictions of movements of people and disruption of transport systems, entries and exits in many States. As a result, corporates and professionals are unable to complete the tasks as they are not able to regularly attend their offices. Working from home has its own limitations.

We, the voluntary bodies of CAs from across India have been approached by several of our members expressing their concerns at the difficulties being faced because of the COVID19 pandemic. Most professionals and their client tax payers are of the view that it is very difficult to meet with the various deadlines for income-tax compliances as their focus right now is on getting their operations on track. Most of the business establishments as well as tax professionals are finding it difficult to operate at full capacity. The shortage of manpower has paralysed the continuity of work. All such issues are making it virtually impossible for most of our members and the taxpayers to adhere to the revised due dates of 31.12.2020. Many of our members in practice are senior citizens for whom it is inadvisable to move out as they are more susceptible to the pandemic.

Extension of due dates under Income-tax Act, 1961:

As per the amendments carried out vide the Finance Act 2020 as also the subsequent notifications, the due dates for filing ITR forms and TAR for AY 2020-21 have been proactively extended to 31.01.2020 and 31.12.2020 respectively. For income-tax assessees who are not subject to any audit (for e.g. salaried taxpayers), the due date for filing the income-tax return for AY 2020-21 stands extended to 31st December, 2020.

During the month of December, there are many other compliances to be made like, filing of DT-VSVA applications (necessary follows ups with department for the same including rectifications, appeal condonations, etc connected thereto) payment of Advance tax, filing of relevant GST returns, GST Annual Returns over & above audit & tax returns. Further, in the ITRs for AY 2020-21, the capital gains transactions have to be reported in great details which is a very time-consuming activity.

Apart from the major issues arising due to COVID19 pandemic hampering compliances regarding filing of ITR forms and Tax audit reports, certain concerns like delay in release of online e-filing utilities & continuous and regular updation in the Schemas of the ITR/TAR Form filing utility and detailed information to be provided in notified ITR forms requires time, needs to be kept in mind for considering the due dates extension.

There is a genuine case for extension of due dates of ITR and TAR, Transfer Pricing report and all other reports under the Income-tax Act for A.Y. 2020-21.

It may be noted that the limitation dates for the completion of income-tax scrutiny proceedings which initially were due in the month of September 2020 have been extended to March 2021. There is no reason why the due dates for the above compliances for tax payers should also not be given the same benefit considering the similar grievances / circumstances.

Extension of due dates under GST Act, 2017:

The current due date for filing the annual reconciliation statement (GSTR9C) along with the annual return (GSTR9) for financial years 2018-2019 & 2019-2020 is 31stDecember 2020.

The clarification in respect of the treatment of certain items to be presented in the GST Annual Return was provided as late as on 9thOctober 2020. Companies and consultants are also occupied in ensuring seamless implementation of the e-invoicing provisions with effect from 1stJanuary, 2021 for a large set of mid-sized taxpayers.

Additionally, the process of preparation of the reconciliation statement and the verification of the claims made by the taxpayer in the said reconciliation statement begins after the financial statements are finalised. For FY 2019-2020, the due dates for filing the financial statements with various regulatory authorities has been extended. Therefore, in the absence of finalised audited financial statements, the process of GST Audit cannot begin. Further, the GST Portal has enabled the filing of the GST Audit Reports for FY 2019-20 only a few days back.

In view of the above mentioned genuine difficulties faced by tax payers of the country, we humbly request you to kindly direct the CBDT to extend all the deadlines under the Income-tax Act for AY 2020-21 to 31st March, 2021 and to extend the due dates for FY 2018-19 & 2019-20 under GST Act also to 31st March, 2021.

Considering the unprecedented situation that all of us find ourselves in at the moment, there is an urgent need for a notification to be issued immediately for the extension of various due dates. If such announcements of extension are made at the eleventh hour, itcauses immense stress and affects the health of all concerned. It may be noted that the filing of the reconciliation statement and the annual return does not involve the payment of any GST. The taxes became due on monthly and quarterly basis and were paid in normal course. The process of filing the reconciliation statement and annual return would only result in small increment tax collections on account of inadvertent omissions made by the taxpayers. Therefore, the grant of the extension in due date is unlikely to have any significant impact on the revenue collections.

CASA representation on TAR and ITR date Extension

Chartered Accountants Social Affiliation (CASA) is a registered NGO, established in the year 2010 is working effortlessly and continuously for the benefits of the Professionals, Trade & Industry by way of imparting knowledgeable webinars by various experts in Industry. Today we have more than 3000 professionals & tax practitioners associated with us pan India. During this financial year starting from April 2020, CASA has successfully organised more than 200 webinars on various topics including that of various Audits under Income Tax Act, Income Tax Returns & many other technical topics under Direct Tax Laws.

We, at CASA believes in taking all the requisite steps and actions to ensure smooth & complete tax and other statutory compliances by the stakeholders. CASA always believes in helping professionals in resolving genuine grievances & effective implementation of law.

Today we are requesting your goodselves to extend the Due Dates for furnishing of Tax Audit Report and Transfer Pricing Audit Report to 28th February, 2020  & Income Tax Return of Assessment Year 2020-21 to 31st March, 2021

Some of the main reasons for requesting to extend due dates are:-

1. COVID-19 Pandemic –

We appreciate the efforts of the Government for the manner in which this pandemic has been tackled & country is saved from community transmission phase of pandemic. We also appreciate the extension provided for Audit Report furnishing & income tax return filing of non audit cases upto 31st December, 2020

But this year whole world has witnessed & is currently witnessing nightmare of COVID-19 pandemic. Due to COVID-19 Pandemic, Govt. had imposed PAN India lockdown from 22nd March, 2020. Although country has been unlocked gradually but the severity & fear of this Corona Virus is not yet reduced. Presently country is passing through 6th phase of unlock but still there are many restrictions on free inter – state movement to a certain extent, time to time night curfew imposed in states like Punjab, Himachal Pradesh, Rajasthan, Gujarat, Madhya Pradesh has hampered intra state movement also.

Due to fear of getting infected, people are hesitant to travel & preferring work from home, many people who went to their native place during lockdown has not returned back to join their duties / offices due to non availability of hostels , mess facility near to their work place, covid fear. Due to this restriction of movement, several industries and private offices are still not able to resume functioning to their full capacity and are still struggling to function at a certain level of normalcy. This also includes the offices of the Chartered Accountants and Tax Practitioners.

Most of the offices are forced to operate with reduced number of staff due to corona related health issues. Access to client data is not available easily. The details required for completing audits and carrying on tax audit and filing the return of income are not being received promptly and thus completion of audit efficiently is taking more than twice the average time it usually takes for completion of any audit.

Further, data verification, analysis, audits etc requires more time and efforts by the professionals.

To conduct the audit efficiently & effectively, Auditor needs to travel to the place of auditee which is very difficult in this pandemic time and exposes them to the risk of contracting this deadly covid virus. Further, the senior citizens including senior professionals and senior assessee are advised to stay at home only. Several Chartered Accountants, Tax Practitioners and there staff have been infected and have not been able to work for minimum of 14 days.

These limitations & restrictions are making it very difficult for the assessee, the Chartered Accountants and the Tax Practitioners to comply with the present extended due dates.

2.     Recent Amendment in Tax Audit Report / Forms dated 01st October, 2020–

Recently CBDT [Central Board of Direct Taxes] has issued Notification No. 82/2020 dated 01-10-2020 notifying Income Tax (22nd Amendment) Rules, 2020  and  making extensive amendments by introducing Form No. 10-IE [for exercise / withdrawal of option u/s 115BAC(5)(i)], Form No. 10-IF [for exercise of option u/s 115BAD(5)] and amendments relating to section 115BA, 115BAA, 115BAB.

The consequential amendments are made in Form No. 3CD [Statement of particulars to be furnished u/s 44AB of Income Tax Act], Form No. 3CEB [Report to be furnished U/s 92E relating to International Transaction(s) and Specified Domestic transaction(s)] and Form ITR-6. These changes are made operative in relation to the Reports / Statement / Form to be furnished for the Financial Year 2019-20.

3.     Delay and / or Non Availability of E Filing Utility of Income Tax Returns and Amended Audit Report / Forms-

ITR Forms / TAR Form / Schema & Validation rules etc are expected to be provided in the month of April. But due to Covid-19 Pandemic, necessary utilities as required for furnishing the data in ITR Forms No. 3, 5, 6 & 7 which is also used by assessee who required to furnish the Tax Audit Report also, are made available in late August 2020 or September 2020 month. There are continuous utility updation are done by the IT Deptt.

Following table shows release date as well as the latest updation date of various ITR Forms-

Income  Tax Return Form	Schema Release Date	Schema Updation Date	Validation Rules (Latest update)	Utility Updation Date           (Excel        & Java)
ITR – 1	02/06/2020	22/09/2020	08/12/2020	01/12/2020
ITR – 2	26/06/2020	04/11/2020	10/12/2020	10/12/2020                     & 01/12/2020
ITR – 3	31/07/2020	09/11/2020	31/07/2020	01/12/2020
ITR – 4	05/06/2020	15/10/2020	08/12/2020	01/12/2020
ITR – 5	25/08/2020	18/11/2020	25/08/2020	03/12/2020                     & 10/12/2020
ITR – 6	22/09/2020	22/11/2020	06/10/2020	03/12/2020
ITR – 7	03/09/2020	08/12/2020	04/09/2020	08/12/2020

Further the Schema / Validation Rules for uploading Form No.3CD electronically were last updated on 25-08-2020. Utility for preparation & furnishing of amended Audit Reports was made available only on 04th November, 2020.

Due to frequent changes in schema or utility, third party services providers will have to upgrade their software which may take about 5 to 6 days to upgrade, depending upon nature of change.

All these amendments of new forms further require more time for the assessee and professionals to carry out the necessary changes for the proper compliance.

Due to pandemic, income tax returns forms were released with delay of almost 04 months & have constantly been updated after such delayed released. Although the utilities were released as on the above mentioned dates, more than 700 paged instructions for filing the return of income were released only on 23rd October, 2020

and these instructions were further revised for better clarity on 22nd November, 2020 i.e. just a month before the due date of filing of income tax return. Professionals and assessee are not provided with enough time to even take a note of the important points.

When the dates were last extended, it was expected that there will be a reasonable resumption of services, however continuous surge in increased cases of COVID in recent past had somewhat resulted in slower unlock & resumption than the expected level. Also due to Farmers’ Protest going on from past 19 days against the New Farm Bill, normal movement of people in Delhi NCR region specially the Delhi borders connecting with UP & Haryana, Punjab is adversely affected due to road closure, traffic diversion etc.

These are indeed unusual times and hence the earlier date of 31st December, 2020 which seemed reasonable at one time is now looking like an impossible.

In view of above genuine hardships & difficulties being faced by the Professionals as well as by the Trade and Industry person, we are requesting your goodselves to consider the above & extend the due dates of furnishing of Tax Audit Report U/s 44AB and Transfer Pricing Audit Report U/s 92E to 28th February, 2021 and Income Tax Return due date to 31st March, 2021 for all type of assessee.

We, alongwith entire fraternity of Audit Professionals and Tax Payers will be highly obliged & appreciate if a timely & prompt decision (well before the present extended date) is taken in this matter.

Chamber of Tax Consultants seeking extension of due dates for AY 2020-21

The Chamber of Tax Consultants, Mumbai & Delhi have requested to Finance Minister for extension of due date for Tax Audit, Transfer Pricing Audit, and Income Tax Return Filing for the Assessment Year 2020-21 as per following request:

The Chamber of Tax Consultants, established in 1926, is one of the oldest non-profit organizations of tax practitioners of Mumbai, having Advocates, Chartered Accountants and Tax Practitioners as its members. Many senior tax professionals who regularly appear before ITAT, high courts and the Supreme Court are its Past Presidents. We have been making regular representations before various government agencies.

The Chamber regularly takes up initiatives to act as a bridge between stakeholders and concerned regulatory bodies in order to convey and help in resolving genuine grievances or effectively implement the laws.

Today, we come forth with a request of extending the due dates of Tax Audit and Transfer Pricing Audit to February 28, 2021 and Income Tax Return filing to March 31, 2021. Our request is based on 2 major pillars:

1. The Covid-19 Pandemic

We commend the Government for the way the pandemic has been efficiently tackled during the various phases of lockdown and unlock. We also appreciate the extension provided for tax audit and income tax return filing up to December 31, 2020.

But, while the country has been unlocked as a whole, several state governments have individually imposed various restrictions based on the spread and severity of the Corona virus in the state. Inter-state movement is restricted to an extent in certain states. The intra-state movement is also restricted. States like Gujarat, Rajasthan, Punjab, Himachal Pradesh, Madhya Pradesh have imposed night curfew. In a city like Mumbai, whose lifeline is its local trains, the metros and local trains are not running till date. The transport via public buses is not easily accessible. Nation-wide, there is still a huge fear of getting infected among the people due to which they prefer not travelling at all or restrict it to the vicinity of their homes. Due to this restriction of movement, several industries and private offices have still not started fully functioning and are still struggling to function at a certain level of normalcy. This also includes the offices of the Chartered Accountants and Tax Practitioners.

Due to this, the details required for completing audits and carrying on tax audit and filing the return of income are not being received promptly and thus the audits cannot be efficiently performed.

Also travelling to the place of audit without availability of trains is very difficult for the professionals and their staff in a city like Mumbai as well as the curfews imposed have curtailed work hours in other cities.

Several Chartered Accountants, Tax Practitioners and there staff have been infected and have not been able to work for minimum of 14 days. Also visiting any audit place all the more exposes them to the virus making them prone to get infected.

In addition to this, the senior citizens are advised to stay at home. This includes senior professionals and senior assesses who following this advice will not be able to comply with the existing due dates.

These hindrances are making it very difficult for the assessees, the Chartered Accountants and the Tax Practitioners to comply with even the extended due dates.

2. Delay in release of utilities and instructions

The utilities for the income tax return were made available only June’20 onwards instead of April’20.

Following is the chart showing the release date and the latest update date:

Sr. No.	Income Tax Return	Schema Release Date	Schema Updation Date	Utility Updation Date
1	ITR 1	June 2, 2020	September 9, 2020	December 1, 2020
2	ITR 2	June 26, 2020	November 4, 2020	December 3, 2020
3	ITR 3	July 31, 2020	November 9, 2020	December 1, 2020
4	ITR 4	June 5, 2020	October 15, 2020	December 1, 2020
5	ITR 5	August 25, 2020	November 18, 2020	December 3, 2020
6	ITR 6	September 22, 2020	November 22, 2020	December 3, 2020
7	ITR 7	September 3, 2020	December 8, 2020	December 8, 2020
8	Form 3CA-3CD	–	November 4, 2020	–
9	Form 3CA-3CD	–	November 4, 2020	–
10	Form 3CEB	–	November 4, 2020	–

Usually, the income tax returns must be released in the month of April but due to the pandemic, the release of the returns have been delayed on an average by 4 months. Additionally, even after release, they have been constantly updated.

Although the utilities were released as on the abovementioned dates, the 700+ paged instructions for filing the return of income were released only on October 23, 2020. These instructions were further revised on November 25, 2020 i.e. just a month before the due date of filing of income tax return, not giving the professionals and assessees enough time to even take a note of the most important points.

These are indeed unusual times and when the dates were last extended one had expected a reasonable resumption of acitvities – however the second predicted phase of COVID spread resulted in a slow unlockdown compared to what was expected and hence the earlier date of December end which seemed reasonable at one time is now looking like an impossibility.

With due respect to the above difficulties faced by the assessees and the professionals, we request your Honour to take them into consideration and extend the due dates for Tax Audit and Transfer Pricing Audit to February 28, 2021 and Income Tax Return filing to March 31, 2021. The entire fraternity of taxpayer and professionals will highly appreciate if this is done soon enough (i.e. well in advance) to allow them to get a clarity.

Western Maharashtra Tax Practitioners’ Association seeking extension of due dates for AY 2020-21

The Western Maharashtra Tax Practitioners Association, Pune have requested to Finance Minister for extension of due date for Tax Audit, Transfer Pricing Audit, and Income Tax Return Filing for the Assessment Year 2020-21 as per following request:

Our Association represents Tax Consultants, Advocates, Chartered Accountants, Company Secretaries & Cost Accountants practicing in direct & indirect taxes from whole Maharashtra state. Presently, we have around 1500 plus active members from the state. Our Association always represents the concerns and problems faced by these members before the respective tax authorities. This initiative of our Association has proved beneficial for the tax administering authorities, our members and ultimately the tax payers at large.

Due to situation of COVID-19 & subsequent lockdown the situation in the country has been totally disturbed. Life of the countrymen has been totally changed & it could not come to normalcy due to various situations existing all over the country.

The no of COVID positive patients in Maharashtra have now started reducing. Though, at every level the efforts to fight out with the pandemic are on. It is also the fact that offices of all tax professionals could start after Unlock-2 phase after 1st July 2020. Though, it is so these offices still could not resume to its full speed as number staff of tax professionals not residing near the place of work but other places have not came back & have not resumed their duties in the offices of tax professionals due to non – availability of mess, hostels at their work places & the most important is fear of the pandemic is still on in the minds of people.

The Central government, all State governments & the local bodies have administered the outbreak of COVID-19 pandemic in an excellent manner all over the countryerefore, the whole country has been saved from the phase of community transmission- he pandemic.

We have faced 2 1/2 months of total lockdown in the whole country. The government has started unlock phases from 1st June 2020. Presently, the country is passing through the 6th phase of unlock after the pandemic. The spread & severity of the Corona Virus has not been reduced. Due to this several restrictions are still continuing in all parts of the country, movement of life is still restricted. Everyone is hopeful that the situation could only normalize after the discovery of vaccine to the virus which is expected soon.

it is also. admitted fact that many tax professionals, accountants of various organizations, businessmen, person responsible of financial affairs in various organisation have been reported COVID-19 positive & hence their work has been hampered. Fear among all class of people of getting infected by the virus results in non–travelling, reduction in effective work time. All these facts results in not functioning / partly functioning of several industrial undertakings, private offices, business units working partly / working from home or not at all working. This includes the offices of Chartered Accountants & Tax Practitioners also.

1. It must be accepted that due to fear of COVID – 19 & also due to actual suffering with the decease many accountants, businessmen & Tax professionals could not pay full attention to the requirement for getting the accounts completed & get them audited. In some cases part records were submitted to the tax auditors but allied information is pending due to various reasons.

2. Due to this the details required for finalising the accounts, filling the tax audit report, payment of balance tax liability could not be completed intime. Travelling to the place of audit of the concerned assessee has also become difficult for the tax professionals & their staff.

3. These hindrances are making it difficult for the Assessee, Chartered Accountants & Tax Professionals to comply with the extended due dates.

4. Your authority was very kind to condiser the fact & extend the due dates as follows:

Particulars	Original due date	Extended due date
For Non audit assessee	31st July	31st December
For filing tax audit report	30th September	31st December
For Compulsory audit under other Acts, Tax audit cases & partners of audit firm assessee	31st October	31st January

5. Due dates for other compliances are overlapping:

1. You will appreciate that extended due date for filing Income tax returns & revised returns for A.Y. 2019-20 was 30th September 2020, which was further extended to 30th November 2020 by your Honour for the above reasons only.

2. The due date for filing of GST Annual return Form 9 for f. y. 2018-19 is extended to 31st December 2020 from 31st October 2020.

3. The due date for filing of GST Audit in from 9-C for f. y. 2018-19 is extended to 31stDecember 2020 from 31stOctober 2020.

4. The due date of holding AGM for corporates has been extended to 31st December 2020 by the Ministry of Corporate Affairs. Therefore, the statutory audit for Companies could also be completed after 30th November 2020.

5. The due date for Income – Tax scrutiny assessments for A.Y. 2018 -19 ending on 31st December 2020 has been extended to 31st March 2021.

6. The due date for Vivad se Vishwas Scheme has been extended to 31st December

All these dates are overlapping each other & compliances thereof by the tax professionals have been very difficult as the priority of each other overlaps. It is therefore requested that the due date for tax audit be extended to 28th February 2021 & the due date for filing Income – tax return to 31st March 2021 at the earliest. This is necessary as presently fraternity of Tax professionals & business entities are under terrible pressure of getting the above compliances done. If this is done immediately the tax professional fraternity & the business class will have clarity of due dates so that they could work more efficiently & could be able to give quality compliances sought by law.

6. Delay in release of return filing utilities:

The utilities for filing income – tax returns were not available on the government sites. Consequently the softwarethereof also could not be released. Following is the chart showing release dates & latest updates of the respective Income–Tax returns filing utilities:

Sr. No.	ITR Form No.	Scheme Release Date	Scheme Updating Date	Utility Updating Date
1.	ITR 1	June 2, 2020	June 15, 2020	July 8, 2020
3	ITR 3	July 31. 2020                            I	August 29, 2020	September 4, 2020
4	ITR 4	June 5, 2020	July 8, 2020	August 12, 2020
5	ITR 5	August 25, 2020		August 25, 2020
6	ITR 6	September       22, 2020		October 1, 2020 (Excel) Java utility not released
7	ITR 7	September         3, 2020		September 3, 2020

The utilities for the Income–tax returns are required to be released on 1st April every year. This is the consistent non – compliance on the part of CBDT officials & the finance department that these utilities are not released on the required date in spite of the various directions from various High Courts from time to time. This year the pandemic has worsened the situation of releasing these utilities.

7. There is additional requirement of filling certain information which was not required in earlier forms.

1. Details of cash portion in Gross receipts,

2. Details of cash portion in Gross payments both as required u/s 44 AB (a), Tax paid u/s 92 CE,

8. Change in forms of Tax audit reports: Vide Notification No. GSR 610 (E) dated 1st October 2020 there are certain changes in tax audit forms applicable from 1st October 2020. This further requires time to comply with the legal requirements by the tax professionals for proper compliance.

It is therefore urged that the due date for filing tax audit report be extended to 28th February 2021 & for filing Income tax return be extended to 31st March 2021. The notification to this effect may be drawn at the earliest in order to comply with the legal requirements by the professionals & the business fraternity in a qualitative way without pressure.

Tax Practitioner’s Association, Indore seeking extension of due dates for AY 2020-21

Tax Practitioner’s Association, Indore have requested to Finance Minister for extension of due date for Tax Audit, Transfer Pricing Audit, and Income Tax Return Filing for the Assessment Year 2020-21 as per following request:

Tax Practitioners Association (TPA), Indore having Advocates, CAs, CS and Tax Practitioners as its members with over 550 members. The TPA regularly takes up initiatives to act as a bridge between stakeholders and concerned regulatory bodies in order to convey and help in resolving genuine grievances or effectively implement the laws.

Today, we have come forward with a request of extending the due dates of Tax Audit, Transfer Pricing Audit, various other Audit Reports under Income Tax Act and Income Tax Return filing for AY 2020-21.

Apart from others, this request is based on following major reasons being:

The Covid-19 Pandemic, Night Curfew, and its effect on professional work:

1. At the outset, we appreciate the earlier extension provided for tax audit and income tax return filing up to December 31, 2020 due to continuing pandemic of Covid -19. The spread and severity of the Corona virus has not been reduced and instead it is rising each day, Night curfew continue, Restriction on Keeping offices open etc. impacting adversely in conducting audit and preparing tax returns. Commuting via public buses/trains and/or other public transport is restricted and not fully operational.

Due to this, several industries and private offices have still not resumed functioning at all. This also includes the offices of the Tax Advocates, CA’s , Tax Practitioners etc. resulting the details required for carrying on tax audit and filing the return of income are not being received promptly and thus the audits cannot be efficiently performed. Further also travelling to the place of audit is very difficult for the professionals and their staff.

Several our members have also been infected and have not been able to work for minimum of 14 days which extends to a month due to post Covid-19 health recovery. Also, visiting any audit place exposes them to the virus making them prone infection. Further, the senior citizens including senior aged professionals  and senior aged assessee are advised to stay at home. These hindrance are making it very difficult for the assessee, the Tax Advocates, CAs and the Tax Practitioners to comply with the presently extended due dates. We would like to appreciate that for the very same reasons that we have cited above, i.e. genuine difficulties being faced by the taxpayers due to outbreak of COVID-19 pandemic, Night Curfew the CBDT has earlier extended the date for filing Tax audit and income tax return filing up to 31st December, 2020 and 31st Jan., 2021 respectively, but the underlying reason of COVID-19 still continuing more vigorously.

2. Delay in release of return filing software utilities:

The utilities for the income tax return were made available only June’20 onwards instead of April’20 and latest on updated during first week Dec., 2020. Usually, the income tax returns are notified in the month of April, but due to the pandemic, the release of the returns also have been delayed on an average by 4 to 5 months. We are submitting the summery return wise as under:

SI.No.	Income Tax Return form	Schema Release Date	Schema Updation Date	Utility Updation date
1	ITR 1	June 2, 2020	September 9, 2020	December 1, 2020
2	ITR 2	June 26, 2020	November 4, 2020	December 3, 2020
3	ITR 3	July 31, 2020	November 9, 2020	December 1, 2020
4	ITR 4	June 5, 2020	October 15, 2020	December 1, 2020
5	ITR 5	August 25, 2020	November 18, 2020	December 3, 2020
6	ITR 6	September 22, 2020	November 22, 2020	December 3, 2020
7	ITR 7	September 3, 2020	December 8, 2020	December 8, 2020
8	3CA-3CD		November 4, 2020
9	3CEB		November 4, 2020	–

Although the utilities were released as on the above mentioned dates, the 700+ paged Instructions for filing the return of income were released only on October 23, 2020. These instructions were further revised on November 25, 2020 i.e. just a month before the due date of filing of income tax return, not giving the professionals and assesses enough time to even take a note of the most important points.

These are indeed unusual times and when the dates were last extended one had expected a reasonable resumption of activities — however the second predicted phase of COVID spread resulted in a slow unlock down compared to what was expected and hence the earlier date of December end which seemed reasonable at one time is now looking like an impossibility.

REQUEST: With due respect to the above difficulties faced by the assessee and the professionals, we request your Honour to take them into consideration and extend  the due dates for tax audit, transfer pricing audit and other audit reports under income tax act as under:

Returns /Audit Reports	Present Due Dates	Requested Due Dates
Tax Audit/TP Audit	31st Dec., 2020	28th Feb, 2021
Income Tax Return (Audit Case)	31st Jan, 2021	31st March, 2021
Income Tax Return (Non Audit)	31st Dec., 2020	28th Feb, 2021

The entire fraternity of taxpayer and professionals will highly appreciate if this is done soon enough (i.e. well in advance) to allow them to get a clarity to. We look forward for your kind consideration to the genuine request.

All Gujarat Federation of Tax Consultants seeking Extension of Due Dates for AY 2020-21

AGFTC, ITBC and CAA has made a Request for further extension of due dates of furnishing Tax Audit Reports/ITR for A.Y. 2020-21 due to spike in Covid cases and consequential delay in notification/amendment of ITR forms/e-filing platform to Ms. Nirmala Sitharaman, Union Finance Minister of India. Text of the Representation is as follows:-

Refer: Our earlier representation dt. 12.10.2020 for extension of due date of furnishing Tax Audit Reports and relevant Income Tax Return up to 31st January 2021

1. We appreciate the emergent steps taken by Government to provide the relief to the people and making all possible efforts for their well being to tackle the challenges faced by the country due to the unprecedented outbreak of Covid-19 Pandemic.

2. To mitigate the hardship faced by the tax payers due to unprecedented situation, government remained proactive by introducing The Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act extending various due dates of statutory compliances. We hereby convey our grateful thanks for partially responding to the representations of our associations, due date for furnishing of various audit reports under the Income Tax Act, including Tax Audit Report and report in respect of international/specified domestic transaction has also been extended to 31st December,2020. The due date for furnishing of Income Tax Returns for the taxpayers (Including their partners) who are required to get their accounts audited has also been extended to 31st January, 2021.

Earlier Representation of our associations for extension of due dates

3. Your kind attention is invited to representation dated 12.10.2020 by our associations requesting your office to direct CBDT [a] To exercise the discretionary power vested in it under section 119 of the Act, by extending the due date of 31st October, 2020 at least for three months up to 31st Janurary,2021 both for filing Income Tax Return and Tax Audit Reports in case of taxpayers whose accounts are required to be audited, to ameliorate the difficulties faced by whole business community and professional fraternity due Covid-19 Pandemic situation and due to delay in notifying return forms/utilities [b] To release the ITR Forms/other Forms, ITR preparation utilities well in advance ordinarily on 1st April of assessment year and not to make changes in forms/utilities after beginning of the relevant assessment year in order to provide seamless period of filing for ITR as provided in Income Tax Law, to avoid hardship to the tax payers and stake holders considering the repeated directives of Hon. Gujarat High Court in [SCA No.12656 of 2014 & SPL No. 15075 of 2015]. In continuation of our earlier representations, we hereby once again encroach upon you precious time, with a request to further extend the due dates of filing Tax audit report/other reports and filing of ITR up to 31st March, 2021 considering following circumstances;

Sudden Spike in cases of Covid-19 Post Diwali Festival

4. In the second wave of the pandemic after Diwali, there has been sudden increase in the number of Covid cases in last few weeks. City of Ahmedabad became the ninth district in India to have crossed 2000 deaths of Covid-19 patients. Complete curfew was imposed in City from 20thNovember, 2020, 9:00 pm to 23rdNovermber, 2020, Monday up to 6:00 am due to spike in Covid-19 cases. All the major districts of the Gujarat are under night curfew from 9:00 pm to 6:00 am till date. There are about 100 containment zone notified by the Police Commissioner of Ahmedabad which will be under complete lockdown till 31st December, 2020. The major share of cases & deaths are contributed by 8 municipal Corporations of Gujarat, including Ahmedabad, Vadodara, Surat, Rajkot, Bhavnagar, Jamnagar, Junagadh and Gandhinagar. Daily covid case growth rate in state is 0.81%-up from 0.75%, a week ago. [Times of India, Abad dt. 13.12.2020]. Hon. Gujarat High Court in its order dated 2.12. 2020 in R/Writ Petition [PIL No. 108 of 2020], expressing concern, observed that, considering the irresponsible behavior of the public at large during Diwali festival resulted is sudden spike in the cases of Covid 19 positive case. The pandemic of Covid-19 continues to spread its tentacles and the number of peoples being affected by it continue to grow each day.

Other states Rajasthan, Punjab, Himachal Pradesh, Madhya Pradesh have also imposed nigh curfew. Local train service, life line of Mumbai is not running fully till date. There are restrictions on interstate movement to certain extent. Due to fear of getting infected people prefer to avoid outside movement.

Impact on audit and statutory compliance work due to Covid Restrictions

5. Due to the risk of Pandemic, restrictions are imposed by the Government /Local Authorities about staggering of work/business hours in offices, work places, shops, markets and industrial & commercial establishment; frequent sanitization of entire workplaces, common facilities and all points which come into human contact. All persons in charge of work places are expected to ensure adequate distance between workers, adequate gaps between shifts, staggering the lunch breaks of staff, etc. Persons aged 65 year or above are not allowed to move outside. All these restrictions coupled with the mandatory quarantine for period of 14 days of family members/other contact persons have placed several limitations on working efficiency/productivity of businesses and professional firms. Several Tax Professionals & Chartered Accountants themselves, their staff, family members, are either bereaved of their beloved ones or infected. Details, information, accounts required for completing audits and filing of I.T. returns are not being received promptly. Audit staff/assistants, who are back bone of doing the tax audit work, preparation of Tax Audit Reports/I.T. returns are feeling low and not able to regularly attend office of Tax professionals. Even clients are facing the similar limitations/restrictions. Till date we are not sure about, when these days will be over and we will be able to function normally.

Impact of Covid-19 Pandemic is visible from Income Tax Returns filing data available on website of I.Tax dept. sourced from e-filing website of I.Tax dept. [Filing Count] is produced hereunder for your kind reference.

Month/Year	2018	2019	2020
April	427535	404902	107292
May	1300439	1401093	240441
June	5997009	5348476	2108368
July	26531425	19509272	4789758
August	19964970	29844440	6032960
September	2412890	2229337	8664255
October	3361314	3783966	6570893
November	793096	1142376	6587041
Total	60788678	63663862	35101008

From the perusal of monthly data and cumulative total of of I.Tax returns e-filed up to November, 2020, impact of Covid restrictions/limitations on the process of I. Tax returns filing can be clearly gathered. During the year 2020 there is substantial decline in the number of I.Tax returns e-filed up to Nov., 2020, as compared to corresponding data of preceding two years of 2018 and 2019 Only 351.01 Lakhs returns are e-filed up to November, 2020 as against 607.89 & 636.64 lakhs respectively, during the years 2018 and 2019.

6. Monthly Statistics of ITR [Form nos 3, 5, 6 & 7] wise receipt of e-returns relevant to the Tax Audit Cases (Source: e-filing website of I. Tax Dept.- Statistics-Filing Counts)

Month/ F. Y.	2019-2020	2020-2021
	ITR-3 (From A.Y. 2017- 18)	ITR-5	ITR-6	ITR-7	ITR-3 (From A.Y. 2017-18)	ITR-5	ITR-6	ITR-7
April	26899	7464	13051	2805	21893	2734	1887	1371
May	117857	4972	4629	1900	56540	8092	5436	3543
June	652694	31176	5034	2433	175660	22378	12077	9884
July	1960622	141565	5136	11044	236676	30304	16626	9427
August	4586535	398458	25109	47090	623920	10673	4883	3174
September	779294	240482	255063	60471	1154410	128305	21633	14441
October	2029779	522327	484424	83673	970999	156087	78903	27283
November	340167	44539	52797	6356	955514	151083	88631	27384
Total	10493847	1390983	845243	215772	4195612	509656	230076	96507
Grand Total	12945845	5031851

The above comparative data of ITR filed by tax payers who are required to get their accounts audited, shows that only about 39% of assessees are able to file their returns in the year 2020 till 30th, November 2020, as compared to preceding year of 2019, when the due date of filing was 31st October, 2019. This data is without considering the increase in number of registered users during the year 2020, actual percentage of filers may be lower than 39%.

Further as per the statistic available on e-filing website of dept., during the year 2019 about 50­55% of returns are filed outside the office hours. Which is not possible during this year, due to night curfew restrictions imposed by several states.

The data clearly warrants the extension of due dates of compliances to save the tax payers from unintended penal consequences of not filling Income Tax returns/Tax Audit Report, due to prevailing precarious situation.

Major reforms on Transparent Taxation-Honoring the Honest, announced by Hon. Prime Minister on dt. 13.08.2020 to make tax processes seamless and painless

7. To reassure the tax payers who contribute to the development of nation, recently Hon. Prime Minister of India Shri Narendra Modi announced the major reforms in administration of Tax System by launching the platform for Transparent Taxation-Honoring The Honest on 13.08.2020,

to provide ease of doing business. Hon. PM assured the nation, to make the processes people centric & public friendly by sensitizing the government machinery to make it pro-people & policy driven. Hon. PM categorically provided the assurance to make tax system and processes as seamless, painless & faceless.

To reassure the citizens that government remains committed to the taxpayers rights and to make them free from harassment of any kind, series of efforts are taken by Finance Ministry to promote digital revolution to usher in transparent taxation system to achieve seamless delivery of service to taxpayer, by enhancing efficiency of tax administration.

Tax Payers’ Charter-Bridge of trust between tax payer and administration

8. To foster the trust between tax payer and the administration, and with the objective of enhancing the efficiency of delivery system of Income Tax dept., Finance Act 2020 enshrined new section 119A in the Act, to empower the Board to adopt & declare a Taxpayers’ Charter to clearly enumerate the

Taxpayers’ rights & duties. Relevant extracts of your Honor’s Budget Speech [2020-2021 presented on dt. 01.02.2020] relating to tax administration are reproduced as under;

Para 81 of Budget Speech – Governance

“Hon’ble Speaker, Sir, all the while I have explained the colour and composition of the bouquet of flowers – schemes and programmes. They were grouped under Aspirational India, Economic Development and Caring India. Now I speak about the two hands that will hold them. One such hand is Governance – clean, corruption-free, policy driven and good in intent and importantly trusting in faith. Trusting every citizen, the aspirational youth, the hard-working women, the risk-taking entrepreneur, the ever hopeful and untiring farmer or the wise and old senior citizen. Many among them are taxpayers. Others may not be taxpayers today. Our Prime Minister has laid before us Ease of Living as a goal to be achieved on behalf of all citizens. An important aspect of both ease of living and ease of doing business is fairness and efficiency of tax administration. We wish to enshrine in the statutes a “taxpayer charter” through this budget. Our government would like to reassure taxpayers that we remain committed to taking measures so that our citizens are free from harassment of any kind.” [emphasis is supplied]

Para 127 of Budget Speech – Taxpayers’ Charter

“Any tax system requires trust between taxpayers and the administration. This will be possible only when taxpayer’s rights are clearly enumerated. Towards this end, and with the objective of enhancing the efficiency of the delivery system of the Income Tax Department, I propose to amend the provisions of the Income Tax Act to mandate the Central Board of Direct Taxes (CBDT) to adopt a Taxpayers’ Charter. The details of the contents of the charter shall be notified soon.”

Delay in issue of forms/utilities by CBDT is not in synchronization of Government’s stated Policy on Tax administration

9. The past experience of taxpayers show that due to delay in notification of ITR/release of utilities/Form 3CD/amendments in rules in mid of the year by DGIT [SYSTEMS]/CBDT, tax payers have to face lot of harassment and after lot of representations by various Professional Associations including Institute of C. A. of India [Dept. of Ministry of Corporate Affairs] and/or after knocking the doors of High Courts, CBDT extended the due date for filing TAR/ITR.

Following table displays the repeated extensions of due dates granted by CBDT after lot of persuasions/representations by tax payers/professional associations or after intervention by Hon. High Courts:

A.Y.	Due dates of filing return of    income  (whose accounts are required to be audited)	Due  date for filing Tax Audit Report	Remark
Original	Extended	Original	Extended
2014-15	30.09.2014	31.03.2015	30.09.2014	30.11.2014	At the instance of Writ by Hon. Gujarat High court
2015-16	30.09.2015	31.10.2015	30.09.2015	31.10.2015	-DO
20c16- 17	30.09.2016	17.10.2016	30.09.2016	17.10.2016
2017-18	30.09.2017	07.11.2017	30.09.2017	7.11.2017
2018-19	30.09.2018	31.10.2018	30.09.2018	31.10.2018	Writ petition filed    before Hon. Guj. High Court and Hon. Court was pleased to issue the notice to Dept., then extension         was announced.
2019-20	30.09.2019	31.10.2019	30.09.2019	31.10.2019
2020-21	31.10.2020	31.01.2021	31.10.2020	31.12.2020	Extension announced subsequent to filing of Writ Petitions before Hon. Gujarat, Bombay and Rajasthan High courts.

10. Delay in Release of the utility to e-file the ITR forms/3CA/3CB/3CD forms for the Ass. Year 2020-21

ITR/ Form	Due date of filing [original]	Date of availability of e-filing utility	Schema updation date	Utility updation date
ITR 1	31.07.2020	02.06.2020	22.09.2020	01.12.2020
ITR 2	31.07.2020	26.06.2020	04.11.2020	10.12.2020
ITR 3	31.10.2020	31.07.2020	09.11.2020	01.12.2020
ITR 4	31.07.2020	05.06.2020	15.10.2020	01.12.2020
ITR 5	31.10.2020	25.08.2020	18.11.2020	10.12.2020
ITR 6	31.10.2020	22.09.2020	22.11.2020	03.12.2020
ITR 7	31.10.2020	03.09.2020	08.12.2020	08.12.2020

Form	Due Date of filing [original]	Date on which rules are amended	Date of updation of utility
3CA, 3CB,3CD	30.09.2020	01.10.2020	25.08.2020/04.11.2020

11. It is submitted that in past, due to delay on the part of CBDT in notifying forms/release of utilities/subsequent amendments in rules and consequential delay in providing E-filing platforms, effective the time limit prescribed/provided by substantive law to tax payer, has been curtailed by the executive. Again for A.Y. 2020-21, due to pandemic effect there has been delay of about 4 months on average in release of ITR Forms/Schema/validation rules and relevant utilities, followed by subsequent updations. Last updation was made on 8.12.2020. About seven hundred paged plus, instructions were released in October followed by revision on 22.11.2020.

Hon. Gujarat High Court in the case of All Gujarat Federation of Tax Consultants V. CBDT [SCA No.12656 of 2014] while extending the due date for filing Tax Audit Report in relation to A.Y. 2014-15, observed that any introduction of new utility/software with additional requirement in the middle of the year, ordinarily is not desirable. Any change unless inevitable, can be planned well in advance. Again Hon. Gujarat High Court in the case of All Gujarat Federation of Tax Consultants V. CBDT [SPL No. 15075 of 2015] issuing directions observed that Board should not create a situation whereby the assessees are required to knock the doors of the court year after year, more so, when on account of the delay on the part of the respondents, it is the assessees who would have to face the consequences of not filing the returns in time. [emphasis supplied]

we submit as under:

12. In view of present times of covid crisis, unrelenting change & uncertainty in operation and administration of businesses, we submit as under;

To provide Ease of Living

i) The Government shall direct that CBDT shall exercise the discretionary power vested in it under section 119 of the Act by extending the due date of 31st December, 2020 at least for three months, up to 31st March, 2021 both for filing ITR and Tax Audit Reports/Other Reports in case of assessees, whose accounts are required to be audited, to provide ease of living to whole business community and professional fraternity in this unpredictable Covid-19 Pandemic situation and on account of delay in notifying the amended rules/forms/return preparation utilities by CBDT, otherwise it would be assessee who would have to face the penal consequences of non filing the Tax Audit Report/ITR in time.

E-filing platform shall be kept ready at the beginning of Ass. Year without waiting for the representations from Tax payers/Associations

ii) Though CBDT has given extension in due dates of filing in past years, after repeated representations from tax payers & persuasion by professional associations, we feel that permanent & principal relief is not given. The Principal and Permanent relief would be when CBDT is directed to strictly follow the Stated Policy & Resolve of Government and abide by assurance given to nation by Hon. Prime Minister, to provide for pain less service to the Tax Payer.

E-filing platform/Utilities shall be kept ready at the commencement of the Ass. Year, without waiting for the representations from tax payer & professional associations, and there shall be no amendment in rules/forms and compliance requirements in mid of the year to make E-filing process Painless and Tax Payer friendly.

iii) At the association level, tax professionals will highly appreciate if the due date for filing of tax audit report & filing of income tax returns in case of assesses whose accounts are required to be audited is extended to 31st March, 2021, which will allow them to focus on filing of income tax returns in case of assesses whose accounts are not required to be audited, filing of declarations under The Direct Tax Vivad Se Vishwas Act, due date for which expires on 31.12.2020 & pursue the assesses to deposit 3rd installment of advance tax for current year. 13. We assure all our support & co-operation in guiding the taxpayers in fulfilling their compliance obligations required by Law.

DTPA representation on TAR and ITR date Extension

we wish to appraise your good self that in West Bengal as also many other States, due to Corona Pandemic normalcy in operations is yet to set in as most of the working force commutes by local train and the local train service has resumed with only partial operations from 11th November, 2020, which makes difficult for work force to reach their office. Many professionals as well as their key staff have suffered infection from Covid -19. Therefore, in most of the offices the Businessmen as well as Professionals are unable to complete their incomplete work and prepare the financial statements for the year ended 31st March 2020.

Furnishing of Tax Audit etc. and submission of ITRs

Respected Madam, as you are aware that the accountants are normally preparing all audit and tax returns data and Audit Assistants of Audit firms do check the same, the compliances related Tax Audit Re-port under section 44AB of the Income Tax Act and ITR submission cannot be completed in spite of best intentions of the owners to do so, as the staff of their offices and also the assistants in the offices of the Professionals are not being able to attend offices.

In so far as Companies cases are concerned, their due date of holding AGM has been allowed extension by MCA and therefore almost all companies are likely to hold AGM by 31st December 2020 and since a copy of the audited report is also attached with the Tax Audit Report, it in nearly impossible to complete the furnishing of Tax Audit Report. The Form 3CD for Tax Audit Report under sec. 44AB as well as Form 3CEB for Report in case of International and specified domestic transactions under sec. 92E have also been recently modified vide Notification No. 82/2020 dated 1.10.2020.

Madam, you will further appreciate that there was a delay in launching the schema of the Tax Audit Report and there have been changes at least three times since it was first launched.

All these problems combined together, it is very sad affairs and people are still not ready with their Ac-counts, Audit and ITR.

Madam, in view of the aforesaid situation, we humbly request to extend the due dates of furnishing Tax Audit Report in Form 3CD and also pray for extension of date for furnishing the Income Tax returns to 31st March, 2021.

Since the specified date and due date are approaching soon, we would appreciate it if your good self would make an early announcement in this matter so that the entrepreneurs and professionals do not un-necessarily expose themselves to too much stress and risk of Pandemic.

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