What’s Extended and What’s Not Extended:
After the release of CBDT Circular No.15/2025 – Income Tax | Dated:29th October, 2025, several doubts and questions have arisen regarding which time limits have been extended and which have not. There have been lots of doubts and questions as to which time limit is extended and what is not extended- As per the CBDT.
Important points to be considered:
1. The circular covers extends the due date for furnishing Income Tax Return (ITR) for the Previous Year 2024-25 (Assessment Year 2025-26) for the assessees referred in clause (a) of Explanation 2 to sub-section (1) of section 139 of the Act.
2. The circular does not extend the due dates for the assessees referred in clause (aa) of Explanation 2 to sub-section (1) of section 139 of the Act
3. Sec 139(1) Explanation 2(a) Includes
i) A company
ii) A person Other than company whose accounts are required to be audited under IT Act or under any other law
iii) A partner of a firm
4. Explanation 2(aa) is not mentioned in the CBDT press release/ circular
Explanation 2(aa) includes
i) Assessee who is required to furnish 3ceb report
ii) Person other than company referred in first proviso
5. Sec 12A(1)(b)(ii) (Section 12A sub section 1 clause b clause (ii))- Refers to the specified date under section 44AB that the person in receipt of the income furnishes the report by that specified date
And
Section 44AB explanation to clause (ii) refers to the specified date as one month prior to due date of ITR filing under section 139(1)
6. In the extension circular no 15- reference has been made to clause (ii) of the explanation to section 44AB and the specified date of furnishing audit report u/s 44AB has been extended to 10.11.2025
7. Furnishing of audit report for section 12A trusts or institutions has also been extended to 10.11.2025
Summary of extension of timelines wrt circular no 15 dated 29.10.2025
1. ITR Date for all tax auditable assesses and companies having tax audit or below Tax audit limit having statutory audits
10 Dec 2025
2. TP Form 3CEB date
31 Oct 2025
3. Tax Audit Date in those cases where TP is applicable
31 Oct 2025
4. ITR date TP cases
30 Nov 2025
(However, this is against one month statutory time gap for TP cases vis a vis ITR due date of filing- may be the same has been skipped or missed the attention while issuing the extension circular)
5. Other than TP Cases, Tax Audit Date
10 Nov 2025
6. Audit date for Trust or Institutions u/s 12A filing audit report
10 Nov 2025
7. ITRs of trusts or institutions as above
10 Dec 2025
While every care has been taken to ensure the accuracy/ authenticity of the above, the readers are advised to recheck/reconfirm the same from the original sources/ relevant departments. It is based upon relevant law and/or facts available at that point of time and prepared with due accuracy & reliability. By the use of the said information, you agree that the company is not responsible or liable in any manner for the authenticity, accuracy, completeness, errors or any kind of omissions in this piece of information for any action taken thereof. This is not any kind of advertisement or solicitation of work by a professional. The company shall in no way be responsible for any loss or damage suffered to any person on account of the same.
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