Tax Bar Association, Guwahati has requested for Extension of Companies Fresh Start Scheme i.e. CFSS 2020 and LLP Settlement Scheme 2020 to to 31st March, 2021. Request is been made to Smt. Nirmala Sitharaman, Hon’ble Minister of Finance & Minister of Corporate Affairs. Full text of the Representation is as follows:-

Tax Bar Association
(Registered under the Societies Registration Act, 1860)
Sreeram Market, 2nd Floor
Chatribari, Guwahati 781001 (Assam)
Email: [email protected]

Date: 21st December, 2020


Smt. Nirmala Sitharaman
Hon’ble Minister of Finance & Minister of Corporate Affairs,
New Delhi

Hon’ble Madam,

Subject: Request for Extension of Companies Fresh Start Scheme i.e. CFSS 2020 and LLP Settlement Scheme 2020 (“Schemes”)

Tax Bar Association, Guwahati (hereinafter referred to as “TBA”) is one of the oldest professional bodies of North East India which was established in the year of 1977 comprising of Advocates, Chartered Accountants, Company Secretaries, Cost Accountants & Tax Consultants as its members. TBA is working dedicatedly and continuously for the benefits of the Professionals, Trade & Industry by way of imparting knowledgeable seminars & webinars by various experts in Industry. As on this day we have more than 450 professionals & tax practitioners associated with us from all over North-East India.

We believe in taking all the requisite steps and actions to ensure smooth & complete tax and other statutory compliances by the stakeholders. We always believe in helping professionals in resolving genuine grievances & effective implementation of law. We wish to bring to your kind notice the following problems being faced by Companies, its directors and professionals associated with them due to the ongoing COVID-19 pandemic and the resultant need to further extend the Schemes.

We appreciate the efforts of the Government for the manner in which this pandemic has been tackled and country is saved from community transmission phase of pandemic. We congratulate and applaud the efforts of Ministry of Corporate Affairs, Government of India for introducing the Schemes vide General Circular No. 12/2020 & General Circular No. 13/2020 dated 30.03.2020 with a view to bestow a chance to all the Companies to complete their pending compliances without the requirement of paying additional fees and penalty, and also to provide immunity from prosecution.

We also highly appreciate the extension of time provided by the Ministry vide General Circular No. 30/2020 & General Circular No. 31/2020 dated 28.09.2020 for the Schemes upto 31st December, 2020. This is a major step in the right direction from the Government which provides an excellent opportunity for all the Companies to regularize their pending compliances and to make a fresh beginning with a clean slate in the statutory compliances as required under Companies Act, 1956 and Companies Act, 2013.

Considering the wide spread outbreak of COVID-19 Pandemic, the Government of India had imposed lockdown throughout the nation from 22ndMarch, 2020. Although the Government of India has taken various steps towards gradual unlocking of the country in phase wise manner, but the severity & fear of Novel Corona Virus is not yet reduced.

With a fear of getting infected with the virus, people are hesitant to travel and during lockdown work from home has also become a new normal especially in service sector. During lockdown many people who have migrated to their native place have not returned back to join their duties/offices due to various reasons. Due to restrictions in free movement of people and vehicles are still in place, 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 Company Secretaries, Chartered Accountants and various other professionals.

Most of the professional 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 preparing required documents, forms and filing of the same with Registrar of Companies (“RoC”) is taking more than twice the average time it usually takes for completion of the assignment. Further, obtaining required information and compiling the same for filing requires more time and efforts by the professionals more so when the professional takes the responsibility about the correctness and fairness of the data submitted.

Moreover, various due dates are falling on 31st December, 2020 including filing of tax audit report under Income Tax Act and considering the limitations & restrictions in place are making it more difficult for the Companies and the professionals to comply with the present extended due dates. We have been approached by many directors of various companies and our professional members expressing their concerns at the difficulties being faced due to COVID-19 pandemic.

Various concerns were raised by the directors and professionals of struck off companies where the filing of required forms could not be done unless and until an order from Honorable National Company Law Tribunal (“NCLT”) is obtained for revival of the company and the same is filed with the jurisdictional RoC for making the necessary changes in the Company Master Data on the MCA portal. Due to the COVID-19 pandemic, working of the NCLT also remained at halt for a long period. Albeit the services of NCLT has resumed in a phased manner and hearings are taking place through Video Conferencing (“VC”) still the situation is far from normal and the NCLT has listed hearings of various revival matters after the expiry of the Schemes.

In view of above genuine hardships & difficulties being faced by the Professionals as well as by the Trade and Industry, we hereby request your good office to kindly consider our request to extend the due dates of Schemes to 31st March, 2021.

We will be highly obliged and appreciate if a timely and prompt decision (well before the present extended date) is taken in this matter.

We look forward for your kind consideration to our genuine request.

For Tax Bar Association

CA. Gopal Singhania 
Ph : 93650-09126; 98640-95646

CS. Narayan Sharma
Corporate Affairs Committee Chairman
Ph : 94350-18319; 70023-55913

Copy to:

1) Prime Minister’s Office, New Delhi;

2) Hon’ble Minister of State for Finance and Minister of State for Corporate Affairs, Government of India, New Delhi;

3) The Secretary, Ministry of Corporate Affairs, Government of India, New Delhi;

4) The Regional Director, North Eastern Region, Ministry of Corporate Affairs, Government of India, Guwahati;

5) The Registrar of Companies, North Eastern Region, Ministry of Corporate Affairs, Government of India, Guwahati;

Download Request for Extension of Companies Fresh Start Scheme i.e. CFSS 2020 and LLP Settlement Scheme 2020

Also Read:-

S. No. Date Association Particulars with link
1 9 Dec 2020 Western Maharashtra Tax Practitioners Extend due dates of Tax Audit & ITR for AY 2020–21
2 12 Dec 2020 Gujarat Sales Tax Bar Extend GSTR-9/9A/9C due date for FY 2019-20 to 30/06/2021
3 12 Dec 2020 Chamber of Tax Consultants Extend due dates for Tax/Transfer Pricing Audit & ITR for AY 2020-21
4 12 Dec 2020 Tax Practitioner’s Association, Indore Extend due dates for filing Tax/TP Audit Report & ITR for AY 2020-21
5 14 Dec 2020 AGFTC, ITBC and CAA Extend due dates of Tax Audit Reports/ITR for A.Y. 2020-21
6 15 Dec 2020 BCAS, CAA (Ahmedabad), CAA (Surat), KSCAA & LCAS Request to Extend Due dates under GST & Income Tax
7 15 Dec 2020 Tax Bar Association, Bhilwara Request to extend Due Date of filing of Tax Audit & ITR
8 15 Dec 2020 Direct Taxes Professionals’ Association, Kolkata Extend due date of ITR & Tax Audit for AY 2020-21
9 16 Dec 2020 Lucknow CA Tax Practioners’ Association Extend Due date for filing Tax Audit Report & ITR
10 16 Dec 2020 Jamshedpur Chartered Accountants Extend Due Date of filing Tax Audit & ITR to 31.03.2021
11 13 Dec 2020 Direct Taxes Committee of ICAI ICAI requests for extension of various Income-tax due dates
12 10 Dec 2020 Udaipur Tax Bar Association Further extend due dates of ITR & Tax Audit Reports for FY 2019-20
13 15 Dec 2020 CA Social Affiliation (CASA) Extend Tax/TP Audit Report & ITR filing due date for AY 2020-21
14 19 Dec 2020 Chartered Accountants Association, Jalandhar Extend Due Dates for Tax Audit and Income Tax Return Filing
15 19 Dec 2020 All India Federation of Tax Practitioners (CZ) Request for extension of due dates of Tax Audit Reports/ITR
16 19 Dec 2020 Vyyapaar Mandal Association, Nagore & AIMTPA Extended Income Tax & GST Audit/Return/Compliance dates
17 17 Dec 2020 Emerging Businesses Chamber Of Commerce Extend due dates for Income Tax Audit & Returns for AY 2020-21
18 Dec 2020 The Uttar Pradesh Tax Bar Association Representation for Extension of time for Tax Audit & Return
19 19 Dec 2020 Tax Bar Association, Guwahati Extend Tax Audit/ITR due dates for AY 2020-21
20 21 Dec 2020 Tax Bar Association, Guwahati Extend due dates of GSTR-9/ GSTR-9C for FY 2018-19 & 2019-20
21 17 Dec 2020 Karnataka State Chartered Accountants Association Waive Late Fees for Delayed Filing of GST Returns
22 15 Dec 2020 Direct Taxes Professionals’ Association Extend Vivad Se Vishwas Scheme due date to 15.03.2021
23 15 Dec 2020 Direct Taxes Professionals’ Association Extend due date of AGM to 31st March 2021
24 15 Dec 2020 Association of Tax payers & Professional, Agra Extend due of GSTR-9, GSTR-9A & GSTR-9C
25 08 Dec 2020 Tax Bar Association (Regd), Allahabad Extend due date of ITR/Tax Audit/GSTR-9/GSTR-9C
26 08 Dec 2020 Tax Consultant & Practitioners Association of Kerala Extend due of ITR, GSTR 9, 9A & 9C for FY 2018-19 & 2019-20
27 21 Dec 2020 Tax Bar Association, Guwahati Extend CFSS 2020 & LLP Settlement Scheme 2020 to 31.03.2021
28 22 Dec 2020 Income Tax Bar Association, Lucknow Extend Time for filing ITR & Audit Report for A.Y 2020-21
28 22 Dec 2020 53 GST and Trade Associations 53 Associations requests Extension for GSTR 9, 9A & 9C
29 16 Dec 2020 Chandigarh Chartered Accountants Taxation Association Extend Income Tax & GST Return & Audit due dates
30 22 Dec 2020 Bhayander CA Social Group Request to extend Due date of Annual GST Return & Audit
31 22 Dec 2020 Luminaires Accessories Components Manufacturers Association Extend due dates for Tax Audit & Income Tax Return filing for AY 2020-21
32 22 Dec 2020 All Professionals, Tax Payers and Stakeholders Open letter for extension of Due dates under Income Tax and GST
33 22 Dec 2020 Punjab Accountants Association Extend due date for filing ITR & Tax Audit Report- AY 2020-21
34 22 Dec 2020 Bhayander CA Social Group Extend Income Tax Audit & ITR Due dates for AY 2020-21
35 23 Dec 2020 The Tax Bar Association, Odisha Extend due dates of Audit Reports, ITRs, GST Returns, VSV Scheme
36 21 Dec 2020 Sales Tax Bar Association, Delhi Extend Tax/TP Audit & ITR Due dates for AY 2020-21
37 23 Dec 2020 Direct Taxes Professionals’ Association Extend Income Tax, Companies & CGST Act compliance due dates
38 24 Dec 2020 ICSI Extend due dates of CFSS, LLPSS, Charge Forms, Meetings
39 24 Dec 2020 All Odisha Tax Advocates Association Extend due date for filing TAR/ITR/GSTR9/9A/9C
40 25 Dec 2020 BJP Economic Cell, Rajasthan Extend Income Tax, GST, LLP, Company Law due dates
41 23 Dec 2020 Hyderabad Chartered Accountants’ Society Extend Due date under GST and Income Tax
42 22 Dec 2020 A. P. Tax Bar Association, Vijayawada Extend date of filing of GSTR 9, GSTR 9C and IT returns
43 03 Jan 2021 National Company Law Tribunal Bar Association Representation for further extension of CFSS 2020
44 25 Nov 2020 Merchants Chamber of Uttar Pradesh Request for extension of Company Fresh Start Scheme 2020
45 04 Jan 2021 Adv. Anuj Bhatt Request to President to take Suo-Moto cognizance of GST Issues
46 03 Jan 2021 The Chamber of Tax Consultants Extend Income-tax due dates with humane approach
47 01 Jan 2021 WMTPA Highly Disappointing GST Audit Due Date Extension
48 01 Jan 2021 The A.P. Tax Bar Association, Vijayawada Extend due date of Form GSTR 9 and 9C for year 2018-19

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