The Pune Chartered Accountants’ Society has submitted a formal request to the Union Finance Minister, Smt. Nirmala Sitharaman, seeking an extension of various statutory due dates for the Financial Year 2024-25. The society’s representation highlights a number of challenges faced by tax professionals and businesses, particularly in the MSME sector. Key reasons cited for the requested extension include persistent technical glitches on the e-filing portal, which have made it difficult for taxpayers to file returns and pay taxes on time. The late release of ITR and audit report utilities also contributed to the delay, along with late availability of tax information from sources like Forms 26AS, AIS, and TIS. The society also points to the significant burden of overlapping compliance deadlines in September and October, the upcoming festive season, and disruptions caused by adverse weather conditions in some regions. To alleviate these pressures and ensure quality compliance, the society has requested to extend the tax audit report deadline to November 30, 2025, and the income tax return filing deadline for audit cases to December 31, 2025, among other extensions for MCA and trust-related filings.
Pune Chartered Accountants’ Society
C/o. M.P. Chitale & Co., 417/1, Narayan Peth, Pune 411 030. Phone 24450156.
Date: 22nd September,2025
To
Smt. Nirmala Sitharaman
Hon’ble Union Minister of Finance and Corporate Affairs,
Government of India
North Block, New Delhi – 110001
Sub.: Representation for Extension of Due Dates for Tax Audit, Form 10B/1OBB, ITR, 12A/80G Re-registration, and MCA Filings (Form AOC-4) for FY 2024-25 (AY 2025-26) from 30th September,2024 to 30th November,2025.
Respected Madam,
We, on behalf of the Pune Chartered Accountants Society, a trust registered with the Office of the Chairty Commissioner, Maharashtra and also u/s 12A of the Income Tax Act, 1961, representing a large number of practicing Chartered Accountants and stakeholders from Pune and adjoining cities, humbly submit this representation requesting Your Good self for the extension of various statutory due dates under the Income-Tax Act, 1961 and under the Companies Act, 2013 falling in September and October, 2025 for the Financial Year 2024-25, relevant to the Assessment Year 2025-26.
1. Reasons for request for extension: –
A. Extension of due date for filing of Non – Audit cases return:
a) Extension of due date for filing of returns of income for non – audit cases from 31St July to 15th September 2025 (later on to 16th September ,2025)
b) Delay in ITR filing utilities (ITR- 2 and 3) which were released on 11th July 2025.
c) The utilities for filing of tax audit reports (Form 3CA/CB and 3CD) were released on 18th July 2025.
d) Utilities for filing of forms 10B/ 1OBB were released on 14th August 2025.
e) Updated Form 26AS/AIS/TIS were made available late i.e.by the end of July,25/ in the beginning of August,25.
f) Although the due date for filing of returns of income for non – audit cases was extended from 31st July to 15th September 2025 and later on to 16th September, 2025, the e-filing portal was suffering from various technical glitches till the last date for filing of returns by those assesses. The waiting time for performing any function through the portal was tremendous. Even challans for payment of advance tax as well as self-assessment tax in some of the cases could be generated after 2 days and without payment details returns could not be filed by the taxpayers. Thus, payments of taxes was also a tough task. OTP for filing of returns also could not be generated. All these technical glitches in the portal led to considerable delay in filing returns of income of non-audit cases.
As a result, the entire staff of CA firms got engaged with non – audit cases of businessmen uptill the extended due date.
Now, with only 12 working days are left in the hands of the auditors and tax practitioners and hence it is extremely difficult to complete the tax audits and to furnish the tax audit reports.
g) It is submitted with regret that the portal is working smoothly on and off even today. Further, as is evident from the data, it can be seen that very few numbers of tax audit reports have been submitted uptill now, which includes mainly of large corporates.
Businesses in MSME Sector largely depends on the external sources of data like AIS, TIS, SFT for finalisation of accounts are the real sufferer since the required information could not be downloaded from the portal due to technical glitches till sufficient period of time. As a result, they could not finalise their accounts leading to non-completion of tax audits in time.
Hence, practically, very few tax audits/ trust audits have been carried out which would result in huge non – compliance, if appropriate relief by way of date extension is not given. Noncompliance would lead to imposition of penalty, late fees, etc. to the taxpayers, most of whom have paid the income tax by way of advance tax, for their no fault.
B. Overlapping Statutory Compliance Burden
The months of September to November 2025 involve several concurrent statutory obligations, including:
a. Tax Audit Reports (Form 3CD)
b. Audit Reports for Charitable and Religious Trusts (Form 106/10BB)
c. Income Tax Returns in audit cases
d. Form 10A/10AB for 12A/80G approval/re-registration
e. ROC Filings: AOC-4 and MGT-7/MGT-7A
f. GST, TDS, PF, PT and other regular compliances.
g. Income Tax Assessments for AY 24-25.
This overlap creates significant time and capacity pressure, on the CA firms handling high volumes with existing staff strength.
C. Technical Issues & Frequent Utility Updates
There have been multiple revisions to the e-filing utilities (including ITRs and Form 106/10BB), as well as functionality disruptions on the MCA V3 portal, affecting the ability of professionals to file reports and returns accurately and on time.
D. Festive Season and Regional Disruptions
Ongoing festivals in the months of September and October ,2025 (i.e., Ganesh Chaturthi, Eid, Navratri, Diwali, Chhath Pooja etc) will lead to working constraints for staff and business houses. Additionally, certain regions in India are experiencing adverse weather conditions (e.g. floods, landslides, poor connectivity) & resultant frequent power disruptions.
Due to uncertain climatic conditions, many people are suffering from illness like cold and cough, fever etc. This is also affecting smooth working of the offices of the auditors, tax consultants as well as of business houses.
2. Summary of Relief Requested (Considering Diwali Festival in 3rdWeek of October,2025)
| Compliance Form | Section | Current Date | Requested Extended Date |
| Tax Audit Reports in Forms 3CA/3CB-3CD | 44AB | 30th September
2025 |
30thNovember 2025 |
| Audit Reports of Charitable Trusts in Form 1OBB/1OBB | 12A / 10(23C) |
30th September
2025 |
30thNovember 2025 |
| Income Tax Returns (Audit Cases) | ITR-
3/5/6/7 |
31st October
2025 |
31stDecember 2025 |
| ITR for Trusts | ITR-7 | 31st October
2025 |
31stDecember 2025 |
| 12A/80G Approval/ Re- registration Form 10A/10AB | 12A/80G | 30th September
2025 |
31stDecember 2025 |
| Filing of Financial Statement with ROC AOC-4/AOC-4 XBRL |
29th October
2025 |
3othNovember 2025 | |
| Filing of Annual return with ROC MGT-7/MGT-7A | 29th November
2025 |
31st December
2025 |
|
| Filing of Audit Report of Transfer Pricing in Form 3CEB | 31st
October,2025 |
3othNovember 2025 | |
| Filing of income tax returns in case of transfer pricing cases | 3oth November
2025 |
31st December
2025 |
3. Appeal in the Interest of Compliance & Fairness
We sincerely believe that the extension of these due dates will:
- Help ensure timely and quality filing
- Avoid unnecessary penal consequences including financial losses in the form of penalty and fine to the business houses, leading to several litigations.
- Support small and mid-sized firms, NGOs, and companies
- Reduce last-minute portal load and stress on systems
- Avoid undue pressures on the health of the auditors and tax practitioners as well as owners of MSME units and their accounts related staff.
- Remove injustice caused to the auditors and tax practitioners as well as MSMEs and small business houses due glitches in the working of the income tax portal in September,2025.
4. Conclusion
4.1 We, on behalf of chartered accountants from Pune and nearby cities, sincerely request Your Honour for kind consideration of this representation and urge you to direct the CBDT as well as Secretariat, Ministry of Corporate Affairs, to issue the necessary circulars/notifications/orders for the extensions of various due dates as mentioned above at the earliest, without waiting for the last date and to give relief to lakhs of taxpayers and tax professionals.
4.2 Here, we wish to bring to Your Kind attention that Circular No.06/2025 for extension of due date for filing of income tax returns in non-audit cases from 31st July,2025 to 15th September,2025 was issued well in advance i.e. on 27th May,2025. We request Your Honour to follow that same pattern for extension of due dates for various statutory compliances as tabled above.
4.3 We wish to bring to your kind attention that, the extension if granted, would not affect the revenue of the Central Government as mostly the taxes have been paid by way of advance tax, but if not granted, it would hamper the business community and the tax professionals adversely.
We take this opportunity to put on records that the Pune Chartered Accountants Society is always acting as a bridge between the Income Tax Department and the tax professionals by arranging joint programmes as well as helping the Department in establishing communication with the tax professionals in Pune.
We remain grateful for your continued efforts towards creating a more facilitative compliance environment.
With highest respect and warm regards,
| For Pune Chartered Accountants of Society | ||
| CA Dinesh Gandhi
President |
CA Abhay Bagmar
Vice President |
CA Shirish Kulkarni
Secretary |
Email: cagandhidb@gmail.com | Mobile: 98225 47432
CC to
1. Honourable Shri Muralidhar ji Mohol,
Member of Parliament, Pune &
Minister of State for Civil Aviation and Cooperation, Government of India.
2. The Chairman,
Central Board of Direct Taxes, New Delhi.
Author Bio
pl date extended