Summary: Maharshi Bharadwaj Chartered Accountants’ Association, Prayagraj, has submitted a representation to the Union Finance Minister seeking a one-month extension of the due date for uploading Tax Audit Reports, including Forms 10B, 10BB, 3CA and 3CB, for Financial Year 2025-26 relevant to Assessment Year 2026-27. The Association appreciates the introduction of a separate 31 August due date for taxpayers having business income but not liable to tax audit, while submitting that the resulting time available for conducting tax audits has effectively been compressed. It states that the existing due date for furnishing Tax Audit Reports is 30 September 2026, followed by the income-tax return due date of 31 October 2026. The representation highlights delayed availability of ITR forms and utilities during the current year, including ITR-3 on 18 June, ITR-5 and ITR-7 on 7 July, and ITR-6 on 4 August 2026, with online utilities becoming available subsequently. It further points to the increased scope and complexity of tax-audit reporting, including reconciliation of books, financial statements, GST records, AIS, Form 26AS, TDS/TCS records, statutory liabilities, MSME information, related-party transactions and cash transactions. The Association also refers to the mandatory detailed financial-statement format prescribed by ICAI for non-corporate entities and the resulting additional compliance burden. It submits that adequate time is necessary for quality professional certification and seeks a permanent legislative solution providing a two-month interval between the non-audit ITR due date and Tax Audit Report due date. As an immediate measure, it requests extension of the Tax Audit Report due date from 30 September 2026 to 31 October 2026.
MAHARSHI BHARDWAJ CHARTERED ACCOUNTANTS’ ASSOCIATION
B-2, Second Floor, Rammohan Plaza, Madhokunj, Katra Prayagraj- 211002 India
O[email protected] @ 8887114233
To
Mrs. Nirmala Sitharaman,
Hon’ble Union Finance Minister,
North Block, Government of India,
New Delhi-110001
Subject: Prayer for one month Extension of due date for uploading Tax Audit Reports-TAR (including in Form 10B/10BB/3CA/ 3CB) as prescribed under the Income Tax Act, 1961 and Rules made thereunder.
Hon’ble Madam,
We respectfully submit as under:
Vice President
APPRECIATION FOR FULFILMENT OF LONG STANDING DEMAND:
1. We appreciate for fulfilling the long standing suggestion by introducing separate due date (from 31st July) for tax payers having business income but not liable to Tax Audit as 31St August.
PRESENT REQUIREMENT OF FURNISHING TAR:
2. The last date for furnishing Tax Audit Reports for Financial year 202526 relevant to Assessment Year 2026-27 is 30′ September, 2026 as per the existing provisions of the Income Tax Act, 1961
CONSEQUENCE OF SHIFTING OF LAST DATE:
The amendment of shifting of last date to 31′ August has resulted in lesser time to conduct Tax Audits, effectively only one month, since Tax Audit Reports needs to be uploaded by 30th September. Thereafter, the ITR needs to be uploaded by 31St October. Needless to mention that gradually audit work and reporting requirements have substantially increased.
DELAYED AVAILABILITY OF ITR FORMS AND UTILITY:
4.1. Respectfully we wish to place on record availability of ITR Forms and
Utilities this year as under:
- ITR-3 – 18th June, 2026
- ITR-5 – 07th July, 2026
- ITR-7 – 07th July, 2026
- ITR-6 – 04th August, 2026
4.2. Thus, the first release of ITR forms during the current year was again considerably delayed, particularly for audit case as is evident from the details.
4.3. Online utilities were made available subsequently, often after a further gap of 15-20 days. Consequently, the effective period available for preparation and filing has been substantially reduced. This is causing considerable practical difficulty to assessee as well as professionals.
INCREASED SCOPE AND COMPLEXITY:
5. There is substantial increase in the scope and complexity of tax-audit reporting in Form No.10B and 3CD. It involve extensive verification and reconciliation of financial and tax information. In addition, the auditor has to reconcile and examine information from multiple sources, including:
Books of account and financial statements;
- GST returns, e-invoices and e-way bills;
- AIS and Form 26AS;
- TDS/TCS records;
- Section 43B/statutory liabilities;
- MSME-related information;
- Related-party and specified transactions; and
- Cash receipts/payments and other statutory disclosures.
ICAI PRESCRIBES FORMAT FOR NON-CORPORATE ENTITIES:
6. It is also pertinent to submit that this year ICAI has implemented a mandatory lengthy financial-statement format for non-corporate assesses. This requires taxpayers to complete and provide substantially more detailed financial statement incorporating information and disclosures. The preparation, compilation, reconciliation and verification of such additional information is considerably time-consuming and has added to the compliance and verification burden on taxpayers and Chartered Accountants respectively.
EXPECTATION OF STAKE HOLDERS:
7. The expectation of all stake holder for Quality of Audit is very high. In this regard, we submit that Tax audit is a professional certification and not merely an electronic filing exercise. Adequate time is essential for proper discharge of responsibility. Excessive compression of the available period result in inadvertent errors and inadequate scrutiny. The situation is further aggravated by electronic filing/portal dependency, validation issues.
PERMANENT SOLUTION:
8. In totality, minimum two-month time is fairly required. Therefore, we respectfully submit that a minimum two-months interval between the last date of non-audit ITR and uploading of Tax Audit Reports should be provided which is practical and reasonable for compliance. We respectfully submit that law should be amended suitably once for all by providing last date to upload Audit Report along with ITR on 31st October only.
PRESENT SOLUTION:
9. The desired two-month interval can appropriately be achieved by extending the Tax Audit Reports due date from 30′ September, 2026 to 31′ October, 2026.
PRAYER:
We respectfully submit that the proposed extension would ultimately serve the interest of all stakeholders, namely, exchequer, taxpayers and the tax-audit professionals.
In view of the above narration, we respectfully pray your honour to kindly direct for extension of due date for furnishing Tax Audit Reports from 30th September, 2026 to 31st October, 2026.
We shall be grateful for such act of kindness for all the taxpayers and professionals.
Yours faithfully,
For Maharshi Bharadwaj Chartered Accountants Association, Prayagraj
