Follow Us:

Tax Bar Association, Guwahati has made a Request for Extension of Due Dates for filing the GST Annual Reconciliation Statement (GSTR-9C) along with the GST Annual Return (GSTR-9) for financial years 2018-2019 & 2019-2020. They requested to Smt. Nirmala Sitharaman, Hon. Finance Minister of India to extend the due dates of furnishing of Annual Return (GSTR-9) and Annual Reconciliation Statement (GSTR­9C) for the year 2018-19 to 31st March, 2021 and that for the year 2019-20 to 30th June, 2021.

Tax Bar Association
(Registered under the Societies Registration Act, 1860)
Sreeram Market, 2nd Floor
Chatribari, Guwahati 781001 (Assam)
Email: taxbarghy1977@gmail.com

Dtd. 21st December, 2020

Smt. Nirmala Sitharaman
Hon. Finance Minister of India
New Delhi — 110001

Respected Madam,

Subject: Request for Extension of Due Dates for filing the GST Annual Reconciliation Statement (GSTR-9C) along with the GST Annual Return (GSTR-9) for financial years 2018-2019 & 2019-2020.

Established in the year 1977, Tax Bar Association, Guwahati 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. Today 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 taxpayers/tax professionals due to the ongoing COVID-19 pandemic and the resultant need to further extend the various due dates under the GST Act for the years 2018-19 & 2019-20.

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 also appreciate the extension provided for Form 9 & 9C for the year 2018-19 upto 31st December, 2020. The whole world has witnessed and 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 many states 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 have not returned back to join their duties / offices due to non availability of hostels, mess facility near to their work place, covid fear, etc. 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 GST Audit and Annual Return 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. We have been approached by many members expressing their concerns at the difficulties being faced because of the COVID-19 pandemic. Most professionals and their client tax payers are of the view that it is impossible to meet with the various deadlines for GST compliances as their focus right now is on getting their operations on track.

The current due date for filing the Annual Reconciliation Statement (GSTR-9C) along with the Annual Return (GSTR-9) for financial years 2018-2019 & 2019-2020 is 31st December, 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 9th October, 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 finalized. Further, the GST Portal has enabled the filing of the GST Audit Reports for F.Y. 2019-20 only a few days back.

The due date for filing the Annual Return & Reconciliation Statement for F.Y. 2018-19 has been extended to 31st December, 2020. However, no extension was announced in respect of F.Y. 2019-20. During the month of December, there are much other compliance to be made like, payment of Advance tax, filing of relevant GST returns, Income Tax Audit & Income-tax returns. These are indeed unusual times and hence it is impossible to file all the required reports and returns within the present due date of 31st December, 2020 which seemed reasonable at one point of time.

In view of above genuine hardships & difficulties being faced by the Professionals as well as by the Trade and Industry, we are requesting you to extend the due dates of furnishing of Annual Return (GSTR-9) and Annual Reconciliation Statement (GSTR­9C) for the year 2018-19 to 31st March, 2021 and that for the year 2019-20 to 30th June, 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
Gopal Singhania
Ph : 93650-09126; 98640-95646
CA. Bikash Agarwala
Indirect Tax Committee Chairman
Ph : 94350-64691

Copy to :

  1. Prime Minister’s Office, New Delhi
  2. Hon’ble Minister of State for Finance, Govt. of India, New Delhi
  3. The Revenue Secretary, Govt. of India, New Delhi
  4. The Dept. of Revenue, Ministry of Finance, Govt. of India, New Delhi 5) The Chairman and members, CBIC

Download Full text of the Representation in PDF Format

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


Join Taxguru’s Network for Latest updates on Income Tax, GST, Company Law, Corporate Laws and other related subjects.


  1. Tej Narayan Mishra says:

    I request to finance minister please give your attention to small business man for extend the Annual return GSTR 4 for 2019-2020 date, otherwise they couldn’t bear the late fees burden

  2. suryanarayanan says:

    Its very important to say the regional gst officers
    to be given power to assisst the clients to clarify and rectify mitakes aften happens while filing 3b and gstr9. atpresent this system is not available.
    Also pl entend the date for 18-19 filing 9.

  3. srivathsan says:

    Extension of due dates may be required now. But to an extent the current extension was enough. More extensions and the Assessees will take some more sweet time to give information to the auditors. In a way extension is more of a headache to the auditors. And moreover many assessees are using the current pandemic situation to their benefit and are just slowing down.Maybe they can extend the other dates like GST and let the auditors concentrate only on the tax audits. Anyways financials of companies should be ready by this month end. So extension in a way may just not be good. I have seen many CAs working very hard with limited staff to finish the filing. The extension if granted will just be an extension of the headache.

  4. RAGHAVENDRA says:


Leave a Comment

Your email address will not be published. Required fields are marked *

Search Post by Date
July 2024