CBDT Circular 14/2025 Sparks Confusion on Audit Report & ITR Due Dates

Confusion in CBDT Circular No. 14/2025 – Extension of Due Date of Audit (TAR) – Due Date of ITR of Audited Assessees

On 25th September 2025, the Central Board of Direct Taxes (CBDT) issued Circular No. 14/2025 extending the “specified date” for furnishing audit reports for Financial Year 2024-25 (Assessment Year 2025-26) from 30th September 2025 to 31st October 2025.

Extract from Circular

“ The Central Board of Direct Taxes (CBDT), in exercise of the powers under section 119 of the Income-tax Act, 1961 (the Act) hereby extends the ‘specified date’ for the assessees referred in clause (a) of Explanation 2 to the sub section (1) of Section 139 of the Act for furnishing of report of audit under any provisions of the Act for the Financial Year 2024-25 (relevant to Assessment Year 2025-26) from 30th September, 2025 to 31st October, 2025. ”

Statutory Framework

Section 139(1) – Explanation 2

In this sub-section, “due date” means,

(a) Where the assessee other than an assessee referred to in clause (aa) is –

(i) A company; or

(ii) a person (other than a company) whose accounts are required to be audited under this Act or under any other law for the time being in force; or

(iii) a partner of a firm whose accounts are required to be audited under this Act or under any other law for the time being in force or the spouse of such partner if the provisions of section 5A applies to such spouse, the 31st day of October of the assessment year;

Section 44AB – Explanation

“ For the purposes of this section,—

(ii) “specified date”, in relation to the accounts of the assessee of the previous year relevant to the assessment year, means date one month prior to the due date for furnishing the return of income under sub-section (1) of section 139. “

Analysis of the Circular

The confusion / defect in Circular 14/2025 arises because:

1. Specified date under Section 44AB is not independently defined; it is linked to the due date under Section 139(1). The due date u/s 139(1) for assessees requiring audit is 31st October. Hence, the “specified date” u/s 44AB is one month prior i.e., 30th September.

2. By stating that the “specified date” was 30th September 2025 and now extended to 31st October 2025, the Circular directly fixes a date — which is technically inconsistent with the law. The statute requires the “specified date” to be derived from Section 139(1), and not to be independently specified.

3. Correct procedure to extend audit report filing: In my opinion, CBDT should have extended the due date under Section 139(1) from 31st October 2025 to 30th November 2025. Only then, by operation of law, the “specified date” u/s 44AB would shift from 30th September 2025 to 31st October 2025.

Resulting Confusion

Because the Circular directly states that the audit report due date is extended to 31st October 2025, taxpayers are left confused about:

• Whether the return filing due date u/s 139(1) for audited assessees remains 31st October 2025 or has also shifted to 30th November 2025.
• Whether the linkage between audit report filing (u/s 44AB) and return filing (u/s 139(1)) is broken by this Circular.

Conclusion

Circular 14/2025, by directly specifying 30th September as the audit report due date and extending it to 31st October, has ignored the statutory design of the Act.

– The specified date cannot be independently stated.
–  It must always remain one month prior to the due date under Section 139(1).
– For effective extension, CBDT should have amended the due date u/s 139(1) for audited assessee to 30th November 2025.

Until further clarification, assessees remain uncertain whether the return filing due date stands extended or not.