The Puzzle of Tax Audit and ITR Due Dates

In the Income-tax law, there has always been a clear and logical arrangement. The Tax Audit Report (TAR) is to be furnished first, and thereafter one month’s time is given to file the Income Tax Return (ITR). That is why, if the audit due date was 30th September, then the due date for filing ITR used to be 31st October.

Meaning of “Specified Date”

Explanation (ii) to Section 44AB:

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

Now, when the CBDT has extended the due date of the Tax Audit to 31st October 2025, it was natural that the ITR date should also have been extended to 30th November 2025. That would have been the simple and straight path. In fact, if the ITR due date was extended to 30th November, then as per the law the TAR date would have automatically adjusted itself to 31st October. This would have preserved the natural one-month gap between audit and return filing.

Circular No.14/2025-Income Tax | Dated: 25th September 2025

But CBDT chose the other route—extending the TAR date itself to 31st October while keeping the ITR date unchanged. The result is that now both TAR and ITR fall on the same day.

Take, for example, a firm whose audit was completed late in the season, on 31st October itself, due to practical issues like pending confirmations, reconciliation of accounts, or delays in receiving necessary information from clients. Under the present scenario, this firm would have to upload its audit report and on the very same day also prepare and file its ITR. This is practically unmanageable because the ITR requires incorporation and validation of the very same audited figures that are being finalized on that date.

I am not saying that it is prudent to complete the audit on the very last date. But even if an audit is completed a week before the due date, the law has always provided one additional month thereafter to file the return. That gap was a practical safeguard against overloading of work and to give reasonable time for return preparation. It was built into the statute itself.

This time, that tradition and legal gap have been disturbed, creating unnecessary pressure on taxpayers and professionals. The simple solution is to extend the ITR due date to 30th November, so that the natural gap between audit and return filing can be restored.

– Sudhir Halakhandi