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All Gujarat Federation of Tax Consultants has made a representation to Ms. Nirmala Sitharaman Union Finance Minister of India and made a Request for extension of due date of filing of Tax Audit Report & Income Tax Return for A.Y.2020-21 as there was delay in notification of ITR forms/release of schema and due to Covid-19 pandemic. Text of the Representation is as follows:-

Ms. Nirmala Sitharaman
Union Finance Minister of India
15, Safdarjung Road, New Delhi – 110029
E-mail id:

Respected Madam,

Sub: Direct Tax Laws- Request for extension of due date of filing of Tax Audit Report & Income Tax Return for A.Y.2020-21- delay in notification of ITR forms/release of schema and Covid-19 pandemic

Ref: Notification No. 82/2020 [F.No. 370142/30/2020-TPL] dated 1.10.2020 issued by Central Board of Direct Taxes [CBDT] amending Tax Audit Report [form 3CD & ITR Forms]

About Associations

1. Income Tax Bar Association, Ahmedabad (ITBA) iS first professional association founded in 1947 comprising of Tax Professionals, Advocates & Chartered Accountants, with membership strength of 950 from all over Gujarat. Chartered Accountants Association, Ahmedabad (CAA) iS carrying on the activities of imparting technical guidance to the Chartered Accountants and engaged in research activities in the field of accounting, tax & allied laws, since 1949. It has dedicated membership of more than 1600 Chartered Accountants from all over Gujarat and India. All Gujarat Federation of Tax Consultants (AGM) founded in the year 1992, is the apex Regional Body of Advocates, Chartered Accountants & Tax Practitioners of Gujarat, having membership strength of more than 1400 professionals and institutional membership across 34 districts of Gujarat.

Above associations are non-profit organizations of Tax Practitioners having membership of many Senior Tax Professionals, who regularly appear before ITAT, High Court and Supreme Court. The prime objective of these associations is not only to work for the cause of its professionals but also educate the public at large and to act as a catalyst between Citizens & Government Authorities.

All Gujarat Federation of Tax Consultants

Goal of Ease of Living

2. Prime Minister has laid before the government, Ease of Living as a goal to be achieved on behalf of all citizens. An important aspect of both Ease of Living and Ease of Doing Business, is fairness and efficiency of tax administration. Finance Ministry has always endeavored to reassure taxpayers that they remain committed to taking measures so that citizens are free from harassment of any kind.


3. This year entire planet has witnessed nightmare year of 2020 since the WHO declared corona virus (Covid-19) as a pandemic on 11.03.2020. India declared complete lockdown of more than 70 days, even today we are battling our way out of pandemic, as number of cases are not flattening/coming down. Due to risk of Covid-19 many business houses are either completely shut or working with lower capacity with limited manpower & staf, due to further restriction imposed by the States or Local Unexpected fall out of pandemic & continuous lockdowns have not only resulted into squeeze in businesses but, on individual level, there has been pain of loneliness, illness, fatigue, mental & emotional stress for many victims of virus and their families. The commutation through Public Transportation is not fully operational. Due to fear of getting infected people avoid travel for longer distances or use of public transport. Several Tax Professionals & Chartered Accountants, themselves have been infected. Due to this staff, articles assistants, who are back bone of doing the tax audit work and preparation of tax audit reports/I.T. returns are not able to regularly attend office of Tax professionals/Chartered Accountants. Even clients are facing the similar limitations/restrictions. Till date we are not optimistic about, when these days will be over and we will be allowed to function normally.

Gujarat vs. Other states

4. As on date more than 70 lakhs corona cases have been detected across the Out of these cases, Gujarat’s tally has crossed the mark of 1.51 lakhs. The major share of cases & deaths are contributed by 8 Municipal Corporations of Gujarat, including Ahmedabad, Vadodara, Surat, Rajkot, Bhavnagar, Jamnagar, Junagadh and Gandhinagar. Even State administration admits that things are not anyway near normal, keeping in view Unlock 5.00 Guidelines.

Proactive Extension of various statutory due dates by Govt.

5. Though, Government has remained pro-active by extending various statutory due dates for different compliances under various laws. The statutory dates for filing of return of income for various categories of assessees are extended from 31.07.2020/30.09.2020 to 30.11.2020 and due date for filing of declaration under VVS scheme is also extended from 03.2020 to 31.12.2020. However the due date of filing Tax Audit Report for assessees, whose accounts are required to be audited is extended just for one month from i.e. 30.09.2020 to 31.10.2020.

Recent CBDT Notification dated 1.10.2020 making amendments in Tax Audit Report/Forms

6. Recently Central Board of Direct Taxes [CBDT] has issued Notification No. 82/2020 [F.No. 370142/30/2020-TPL] dated 1.10.2020 making extensive amendments in the rules by introducing Form No. 10-IE [for exercise/withdrawal of option u/s 115BAC(5)(i)] & Form No. 10-IF [for exercise of option u/s 115BAD(5)] and amendments relating to section 115BA, 115BAA, 115BAB. The consequential amendments are made in Form No. 3CD [Statement of particulars to be furnished u/s 44AB] by insertion of various clauses. These changes are made operative in relation to the tax audit of accounts of F.Y. ended on 31.03.2020, due date of furnishing the Tax Audit Report for these cases fall on 31.10.2020.

7. The above amendment in Form No. 3CD/ITR forms are required to be explained to the tax payers to facilitate the compilation of required data & complete reporting. Tax auditor is also tasked to furnish the opinion on certain interpretational issues involving detailed verification, compilation of voluminous data & in particular, relating to reporting in adjustment of WDV of assets & carry forward of losses chart. The Institute of Chartered Accountants of India, apex body of Chartered Accountants is required to upgrade the guidance note on revised form no. 3CD in order to ensure uniformity in reporting.

Delay in release of utilities required for preparation of ITR Forms

8. Normally ITR forms/TAR Form/Schema & Validation rules are expected to be provided in the month of April. But due to Covid-19 Pandemic, utilities required for furnishing the data in ITR Forms No. 3, 5, 6 & 7 used by assessees, required to furnish the Tax Audit Report are provided on 09.2020 and 1.10.2020 and Java utility for preparing Form no. 6 is provided on 10.10.2020. The Schema/Validation Rules for uploading form no.3CD electronically were last updated on 25.08.2020. Any user who file e-return will have to create an XML file based on the schema. The schema is needed by those, software companies and organizations who wish to use this code to help create their own software utility for filling up these forms. Due to frequent changes in schema or utility, third party services providers will have to upgrade their software which may take about 5 to 6 days to upgrade, depending upon nature of change.

With the issue of above stated notification on 1.10.2020, amending the ITR Forms and Form 3CD-Tax Audit Report, further amendments in Microsoft Excel, Java utilities & ITR Schema/Validation rules will have to be provided by the Income Tax Department.

9. Gujarat High Court in the case of All Gujarat Federation of Tax Consultants V. CBDT [SCA No.12656 of 2014] while extending the due date for filing Tax Audit Report in relation to A.Y. 2014-15, observed that any introduction or new utility/software with additional requirement in the middle of the year, ordinarily is not desirable. Any change

unless inevitable, can be planned well in advance. Keeping in focus such comprehensive process re-engineering may result in undue hardship to the stake holders.

Again in the case of All Gujarat Federation of Tax Consultants V. CBDT [SPL No. 15075 of 2015], while extending the due date of filing Tax Audit Report in relation to A.Y. 2015-16 for one month, also directed the Board, that forthwith the respondents shall henceforth, endeavor to ensure that the forms and utilities for e-filing of income tax returns are ordinarily made available on the 1st day of April of the assessment year. Rule is made absolute to the aforesaid extent. Hon. Court, further observed that the Board is expected to exercise the discretionary powers vested in it under section 119 of the Act to ameliorate the difficulties faced by the assessees on account of no default on their part. The Board should not create a situation whereby the assessees are required to knock the doors of the court year after year, more so, when on account of the delay on the part of the respondents, it is the assessees who would have to face the consequences of not filing the returns in time.

Request for extension of due date for filing TAR/Relevant ITR Forms

10. Though, due to Covid-19, CBDT has extended the due date for filling Tax Audit Report from 30th September to 31st October 2020, in case of assessees, who are required to get their books of account audited. It is requested that CBDT shall exercise the discretionary power vested in it under section 119 of the Act by extending the due date of 315t October, 2020 at least for three months, up to 31st Janurary,2021 both for filing ITR and Tax Audit Reports in case of assessees whose accounts are required to be audited, to ameliorate the difficulties faced by whole business community and professional fraternity due Covid-19 Pandemic situation and on account of delay in notifying the amended rules/forms/return preparation utilities by CBDT, otherwise it would be assessee who would have to face the consequences of non filing the Tax Audit Report/ITR in

11. The Ministry of Corporate Affairs, responding to various representations from the Companies, Industry Bodies and Professional Institutes, due difficulties faced in view of Covid-19 Pandemic, has given extension to companies for holding Annual General Meeting for the period of 3 months.

12. At the association level, tax professionals will highly appreciate if extended due dates are notified immediately, well in advance, that will allow them to focus on filing of ITRs in cases where accounts are not required to be audited. We assure all our support & co-operation in guiding the taxpayers in fulfilling their compliance obligations, making honest & full disclosure as per applicable tax law in timely manner.

Thanks & Regards,

Yours Truly,

AGTF Office BeareresAhmedabad

Dated: 12.10.2020

Copies To: (Respected Sirs, with a request to do needful in the matter)

1. Minister of State for Finance,
North Block, Parliament Street.
New Delhi – 110001

2. Hon. Chairman
Central Board of Direct Taxes,
Ministry of Finance,
North Block, Parliament Street.
New Delhi – 110001

3. Joint Secretary, Tax Policy and Legislation
Ministry of Finance,
North Block,Parliament Street.
New Delhi – 110001 E-mail :

4. Chief Commissioner of Income Tax, Gujarat (CCA)
Aayakar Bhavan,
Ashram Road,
Email ID:

303, B wing, Pratyaksh Kar Bhavan,
Nr. Panjrapole, Ambawadi, Ahmedabad-380 015. Ph.: +91 9825 5652 82

Download Representation in PDF Format

Also Read Other Similar Representations:-

S. No. Dated Made by Link to View the Representation
1. 06/08/2020 C.V.O. Chartered & Cost Accountants’ Association Representation for relaxation from levy of Section 234A interest
2. 25/08/2020 C.V.O. Chartered & Cost Accountants’ Association Suggestion /representation on 7 Important Direct Tax Issues
3. 04/09/2020 All India Federation of Tax Practitioners
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Extend due date of filing Income Tax Returns & Tax Audit Report
4. 05/09/2020 National Association of Tax Professionals
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5. 24/09/2020 Zalawad Federation of Trade & Industries Roll-back provisions of TCS under section 206C(1H)
6. 23/09/2020 Lucknow Chartered Accountants Society, Bombay Chartered Accountants’ Society, Chartered Accountants Association (Ahmedabad), Chartered Accountants Association (Surat) and Karnataka State Chartered Accountants Association TCS- Section 206C(1H)- Request to Provide relief & Clarification
7. 13/09/2020 Extend timeline for filing of Return, Tax & Transfer Pricing audit
8. 31/09/2020 Ahilya Chamber of Commerce and Industry Withdraw New Income Tax TCS provisions
9. 07/10/2020 Chamber of Tax Consultants Extend Due Dates for filing Tax/Transfer Pricing Audit & ITR
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11. 11/10/2020 संभागीय चैम्बर ऑफ़ कॉमर्स एंड इंडस्ट्रीज भरतपुर (राजस्थान) Extend GSTR-9, GSTR-9C ITR & Tax Audit Due dates
12. 12/10/2020 All Gujarat Federation of Tax Consultants Extend due date of filing of Tax Audit Report & Income Tax Return
13. 13/10/2020 Tax Practitioners Association, Indore Extend dates for filing Tax Audit Report & ITR for AY 2020-21
14. 14/10/2020 Tax Bar Association, Bhilwara Extend Due Date of filing of Tax Audit & Income Tax Return
15. 14/10/2020 Gujarat Chamber of commerce & Industry Extend due date to submit Tax Audit Report & ITR to 31.12.2020
16. 15/10/2020 Karnataka State Chartered Accountants Association Extend due date for filing TAR to 28.2.2021 & ITR to 31.03.2021
17. 13/10/2020 All India Federation of Tax Practitioners (CZ) Request to extend date of filing Income Tax Audit for FY 2019-20
18. NA Tax Consultant’s Association, Jaipur Extend due date for submitting Tax Audit Report & IT Returns
19. 10/10/2020 Udaipur Tax Bar Association Further extend due dates for filing of both ITR & TAR
20. 08/10/2020 Tax Bar Association, Alwar Extend due date to submit Tax Audit Report & IT Returns
21. 07/09/2020 Tax Bar Association, Kota Extend due date for submitting Tax Audit Report & filing IT Returns
22. NA Nagpur Chamber of Commerce Limited Extend due date for filing of Tax Audit reports, TP Audits & ITR
23. 21/10/2020 Lucknow Chartered Accountants Society, Bombay Chartered Accountants’ Society, Chartered Accountants Association (Ahmedabad), Chartered Accountants Association (Surat) and Karnataka State Chartered Accountants Association Extend Income Tax and GST Audit & Return Filing dates

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  1. Ganapaiah Vasudeva says:

    Dear All, Tax audit under income tax, due date for filling return should be extended atleast by 28 Feb 2021. In this covid-19 Pandemic situation there will be a heavy rush in Tax practioners, CA’s offices and not availaibility of Datas with business organisations and also new acts, new forms, not availability of staffs etc, we tax practioners are under heavy mental and physical stress. The Finance ministry is sleeping and it is observed that they may give extension only on last day of October. Why can’t they ammend the due date early in advance so that filling of Tax Audit and ITR will become ease to Tax practioners.

  2. BAABU says:

    DEAR ALL, It seems that our request is not enough to make them understand the situation. Every year this Finance Ministry will give us tension especially for tax audit part of filing. We should ask for permanent fixation of filing date every year 31st december only…Dont you think?


    Further, 43B payments tax, bonus etc can be paid on or before due date of return, if payment is unpaid till Tax audit filing date. Deptt. system how treat God know??????????

  4. S SHARMA says:

    The Govt is absolutely insensitive about the plight of the common population. FM sits in airconditioned office and dictates to secretaries. They think that the professionals have a magic wand to complete tasks in a whiff. Date should have been extended long back, but even now they are playing with the citizens. Shame

  5. Anil Raichura says:

    Yes ,Agreed to extend tax audit date in this COVID-19 PANDAMIC otherwise we should go to court and should file writ petition at earlier stage

  6. Shriya says:

    The date should be extended to 31st March 2021.
    Seeing the pandemic situation it is very difficult to audit the books of accounts, also articles are on leave who are having exams in November and unfortunately the dates of exams have also been extended so it will now take a much longer time then earlier as the staff won’t be available. So we request to please extend the date as soon as possible



  8. Vijay Paikoti says:

    When the due date for AY19-20 also is extended to 30th Nov and the due date for non tax audit returns for AY20-21 is also 30th Nov tax professionals are burdened with the backlog of AY19-20 and also of AY20-21. In the midst of this to give justice to the tax audit work will not be satisfactorily possible and it requires extended time without any pressure of other non audit returns to give justice to the audit work.

  9. Chaitali Sinha says:

    To our honourable Finance Minister, we will be highly grateful if Income Tax Returns And Tax Audit for Assessment Year 2020-21 be extended further, on account of this pandemic situation.

  10. BAABU says:

    Dear All, Every year we are facing problem in IT FILING especially for TAX AUDIT returns. Where heary compliance and work needed for this returns , for this only they allot only short time, We have to reconcile each statutory reports and GST Reconciliation becoming heavy HEADACHE .. after tallying GST only we can update the IT RETURNS matters. But why Govt can not understand this and every time they are making us begging for extension of time. Where for individual returns they are giving lot of time. Why this king of unscientific allotment of time they do? Actually every year they should give time till 31st december only. And this time due to covid 19 reasons all CA and consultants office staffs are discontinued and moved to their natives. And our clients work place employees also most of them left the job it self. in this situation procuring the data for auditing it self is a big headache. This practicle problem why FM or GOVT never think and making us tension every year. and what do they get by doing this.. This all we have to condemn and not to REQUEST but DEMAND for extension of time for filing returns for TAX AUDIT cases..

  11. R. Sridhara Murthy says:

    Even government can waive off filing of IT returns for senior citizens, retirees whose income falls below 10 lakhs due to the serious covid 19 pandemic situattion.

  12. Protiv Kumar Chakraborty.Advocate says:

    With due respects against above petition all types of ITR submission with Tax Audit & Without Tax Audit should be extended till 31.03.2021 initially basis due to Covid-19 situation and in the month of March,2021 It should be extended again on basis of the pandemic situation.

  13. SANJEEV JAIN says:

    Well known by everybody that Covid issue is not yet resolved and people are still afraid to come out to the office . The income tax department has itself extended all limitations for their work till 31/3/21 , even those which expired on 31/3/20. In these circumstances , there should be extension of the date of filing audit report as well as returns of audited assesses by at least 3 months.

  14. A.Senthil Subramanian says:

    Much needed one. FM Madam is highly supported to Tax professionals(?). We saw it in earlier periods. We are very blessed peoples doing taxation works in this Golden Period (?) . By Oct 31 eve 5 o’clock we may get a good result. Very sorry to say this.

  15. says:

    It is but obvious if the Govt. need complete Audit reports in new pattern then should extend the due date of all compliance . Professions are working without proper staff due to Covid-19. Strongly support this request.

  16. Svs says:

    A better way would be to simmultaneously declare an Income tax holiday for FY 2020- 21
    For income up to Rs 15 lakh
    to bring back demand in the market.

  17. P.K.KUNDU, ADVOACTE says:

    Tax Audit Report [form 3CD & ITR Forms] etc.for asst. year 2020-21, due date should be extended up to 31st March,2021 on account of this serious
    covid19 pandemic situation.

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