Karnataka State Chartered Accountants Association (KSCAA), a professional body established in 1957, has submitted a representation to the Central Board of Direct Taxes (CBDT) highlighting an anomaly in Circular No. 15/2025 and the Press Release dated 29 October 2025 regarding the extension of due dates for filing Income Tax Returns (ITR) and audit reports for Assessment Year 2025-26. KSCAA appreciated CBDT’s decision to extend the due dates for assessees covered under clause (a) of Explanation 2 to section 139(1) — extending ITR filing to 10 December 2025 and audit report submission to 10 November 2025, a move that eased compliance pressure. However, KSCAA pointed out that the circular omitted a similar extension for assessees covered under clause (aa), i.e., those required to file the accountant’s report under section 92E (Form 3CEB) related to international and specified domestic transactions. This omission creates an inconsistency, as taxpayers with more complex transfer pricing obligations must comply earlier (by 30 November 2025) than those with simpler audits, undermining uniformity and fairness. KSCAA urged the CBDT to rectify the anomaly by extending corresponding relief to 92E assessees to maintain equitable treatment across all audit-related categories. The representation emphasizes the need for consistency and uniformity in deadline extensions, aligning with CBDT’s established practice of facilitating taxpayer convenience and reducing compliance hardship.
KARNATAKA STATE CHARTERED ACCOUNTANTS ASSOCIATION (R)
To,
Shri Ravi Agarwal,
The Chairman,
Central Board of Direct Taxes (CBDT),
New Delhi.
Date: Friday, 31 October 2025
Ref No: 003/2025-26
Respected Sir,
Subject: Representation regarding anomaly In CBDT Circular No. 15/2025 and Press Release Dated 29th October 2025 regarding Extension of Due Dates for Assessees Covered Under Section 92E for Assessment Year 2025-26
The Karnataka State Chartered Accountants Association (R) (KSCAA), established in 1957, is a premier professional body representing the Chartered Accountancy profession in Karnataka. With a legacy of fostering professional excellence, we have actively collaborated with the Income Tax Department, Central Board of Direct Taxes (CBDT), and other stakeholders through seminars, workshops, policy consultations, and representations to facilitate seamless tax compliance, promote economic growth, and uphold principles of transparency and efficiency in tax administration. KSCAA continues to serve as a bridge between professionals and policymakers, contributing to the development of a robust and practical tax ecosystem.
We sincerely appreciate the CBDT’s positive step in issuing Circular No. 15/2025 dated 28th October 2025, which extends the due dates for furnishing Income Tax Returns (ITR) and audit reports under section 44AB for assessees referred to In clause (a) of Explanation 2 to sub-section (1) of section 139 of the Income-tax Act, 1961 (the Act). We are particularly thankful that, despite various High Courts extending the dates only up to 31st October 2025 for furnishing audit reports and 30th November 2025 for ITRs, the Board has been considerate in further extending the ITR filing date to 10th December 2025 and, consequently, the specified date for furnishing audit reports under the provisions of the Act to 10th November 2025. This measure is a welcome step that significantly eases compliance pressures for a large section of taxpayers.
At the same time, we wish to draw attention to an apparent omission in not extending similar relief to assessees covered under clause (aa) of the same Explanation, namely those assessees who required to furnish the accountant’s report under section 92E (Form 3CEB) in respect of international or specified domestic transactions in the said circular. This has created an unintended anomaly on the applicability of the extended timelines to such assessees, potentially leading to unintended compliance inconsistencies.
BACKGROUND AND REFERENCE TO Circular No. 15/2025
CBDT Circular No. 15/2025 dated 29th October 2025, issued under section 119 of the Act, states as follows:
“The Central Board of Direct Taxes (CBDT), in exercise of its powers under section 119 of the Income-tax Act, 1961 (the Act), hereby 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, from 31st October 2025 to 10th December 2025. Consequently, the specified date for furnishing of report of audit under the provisions of the Act for the Previous Year 2024-25 (Assessment Year 2025-26) shall stand extended to 10th November 2025 in terms of clause (ii) of the Explanation to section 44AB of the Income-tax Act, 1961.”
This follows the CBDT Press Release dated 29th October 2025, announcing extension of due dates for certain category of assessees The extended due dates have been positively received by stakeholders. However, both the Press Release and Circular are silent on the treatment of section 92E assessees, who face a higher compliance burden due to transfer pricing documentation and reporting requirements. This omission appears to be an inadvertent lapse, as it results in an anomalous situation where companies having transfer pricing compliance obligations are required to file their Income Tax Returns by 30th November 2025, while other audit cases without such additional compliance are permitted to file up to 10th December 2025. This effectively mandates earlier compliance from taxpayers with greater statutory responsibilities, which is inconsistent with the principle of fairness and the Board’s established practice of providing uniform relief across audit-related categories.
PRAYER
We respectfully urge the Board to kindly examine and address the above anomaly to ensure parity and equitable treatment for all categories of assessees subject to audit-related compliances under the Act. We are confident that the Board will appreciate the practical implications of the current position and take suitable steps to remove the inconsistency, thereby upholding the spirit of uniformity and fairness that has consistently guided its approach in matters of taxpayer facilitation.
Yours sincerely,
For Karnataka State Chartered Accountants Association
CA Shivaprakash Viraktamath
President
CA Siddartha S Jawali
Secretary
CA Babitha G
Chairperson
Representation Committee
CC:
1. Smt. Nirmala Sitharaman, Hon’ble Union Minister of Finance and Corporate Affairs, Government of India
2. Shri Pankaj Chaudhary, Union Minister of State for Finance
3. Shri Arvind Shrivastava, Hon’ble Revenue Secretary
4. Smt Preeti Gars, PCCIT, Karnataka and Goa
