Tax Bar Association, Jodhpur made a Request for Extension of due date for filing of Tax Audit reports and Income-tax returns from 30th September 2019 to 30 November 2019 to Smt. Nirmala Sitharaman, Hon’ble Union Minister of Finance & Corporate Affairs. Text of the Representation is as follows:-

Dated: 16/09/2019

JODHPUR (Rajasthan)

CA.Vishnu Prakash Daga
102, Manji ka Hatha, Paota,
Opp. BSNL Office
Tel. (O) 2546240
M: 93147-46240
E-mail: [email protected]
CA.Raj Bothra
155, Patrakar Colony,
New power House Road,
Tel. (O) 2623707
Mobile: 93147-10770
E-mail: [email protected]


1) Nirmala Sitharaman
Hon’ble Union Minister of Finance & Corporate Affairs
Government of India, North Block,
New Delhi-110001

2) The Chairman
The Central Board of Direct Taxes

3) Prime Minister Office
New Delhi

Hon’ble Madam,

Greetings of the Day!

Sub.: Request for Extension of due date for filing of Tax Audit reports and Income-tax returns from 30th September 2019 to 30 November 2019.

Tax Bar Association, Jodhpur hereby takes the privilege to address the concern of the members, being Chartered Accountants, Advocates and Tax Practitioners, practicing in the area of indirect taxation which are of utmost importance and need to be addressed by your good office on utmost priority.

There is sufficient cause and need for extension of last date of filing Income tax Returns for a reasonable period not less than 30th November 2019.

Due to the following reasons a case is made out for extension of above date.

1. Return forms (in pdf form) for assessment year 2019-20 were released in first week of April , 2019 but return preparation software (RPU) were made available for different forms on different dates upto June, 2019. Following table clears the picture as to when utilities were released


Date of Release of RPU


May 10, 2019


May 28, 2019


July 08,   2019


June 04, 2019

Ideally speaking, the utilities should have been made available by 01.04.2019. But as you can see from above table, the above utilities were available much after 01.04.2019. In case of ITR 6 the delay in release of utility was as long as 98 days.

2. Similarly, instructions for filling up ITR forms were released in a staggered manner on different dates. Without following instructions a return cannot be filed correctly.

3. Further, Return Filing Utility provided on e filing site is continuously being updated. Utility for filing ITR-3 , ITR-3 and ITR-7 just changed on 12.09.2019. [ Screenshot attached]

filing ITR-3 , ITR-3 and ITR-7 just changed on 12.09.2019

From table below your goodself can have snapshot of different release dates of relevant utility for filing of return by 30.09.2019

ITR Release Date of the Latest Version of Excel Utility Release Date of the Late of Java Utility
ITR 3 September 12, 2019 September 12, 2019
ITR 5 August 7, 2019 August 6, 2019
ITR 6 August 14, 2019 September 12, 2019
ITR 7 August 19, 2019 September 12, 2019

It can be thus be seen that most of the RPUs applicable to the assessees whose returns are due on September 30, 2019 have been updated on September 12, 2019 i. e. just before 18 days from the due date of filing.

Every updation leads to a further delay as the same has to be updated on software used by the stake holder.

4. On demand from various stakeholders, including this association, around the country, your goodself has extended due date for filing income tax returns in non-audit cases from 3 1.07.2019 to 3 1.08.2019. We thank you for that. But after that extension time left for preparing and filing of returns and tax audit reports have left of one month only, which as per law itself shall be of clear two months. Due to the voluminous data required to be compiled by assesses covered under tax audit as well as by companies, it is very difficult to complete the filings of both the tax audit report and income tax return in half the time period against 2 months as mandated by the law.

5. As per law facility for filing ITR be ready on First day of April of the assessment year so that assessees get sufficient time to collect information desired in IT forms and file it properly.

Since this year there is enormous delay on part of department to provide IT forms preparation software, Dynamic amendment of Return Preparation Utility, TDS details and instructions for filing ITRs a case is made out for extension of due date.

Therefore, we request an extension of at least two months  of due date for filing ITR and tax Audit report to  30.11.2019.

Kindly look into above at the earliest and announce the extension immediately and relieve the professional fraternity like ours from unwarranted stress.

Continuing Suggestion:

1) Time and again, citizens and various forums of the country have been requesting that all relevant compliances and the procedures including the forms shall be made available to the concerned class well before start of the financial year so that necessary data can be built in the desired format and purpose. Its time and again that Government bodies overlook this aspect and the ‘Ease of Doing Business’ objective propagated by the Government becomes a hypocrite punch line. Each day a new amendment / updation not only in Income tax law but various other commercial laws makes the life tough and the small businesses are into more of Government business of compliances rather than their actual business. Even various High Courts have advised the Government in this regard while extending last dates through writs in the matters of Income tax audits, etc.

Tax Bar Association is of the belief that in a democratic country, the People of the country are the supreme authority and it is confident that the Government will not suppress the concerns of its People. We understand that the Govt. is well aware of the above facts and will definitely consider the above representation of date extension.

We would be thankful if your goodself judiciously extend the date well in advance which will keep the members relieved from last minute unwanted stress and would be effective and meaningful.

Yours Faithfully,
A Definite Partner in Nation Building
Tax Bar Association, Jodhpur

Vishnu Prakash Daga

CA. Manoj Gupta
Joint Secretary & Co-ordinator

Raj Bothra

Download Representation by  Tax Bar Association, Jodhpur

Dated Submitted by Link
16.09.2019 Tax Bar Association, Jodhpur As above
16.09.2019 The Chamber of Tax Consultants Extend due date to file income tax return and tax audit report
13.09.2019 All India Federation of Tax Practitioners Extend due date to file ITR & tax audit reports by one month
11.09.2019 All Gujarat Federation of Tax Consultants Extend Tax Audit and related ITR Filing Due Dates
19/08/2019 BCAS and 4 Others Representation on Income Tax and GST Issues faced by taxpayers
13/08/2019 Goods & Services Tax Practitioners Association of Maharashtra Extend GST, Income Tax and other due dates falling in Aug & Sep 2019
10/08/2019 Karnataka State Chartered Accountants Association Extend Due Date for Filing of Income Tax and GST Returns
18/07/2019 Tax Bar Association, Jodhpur Extend due date for filing of Income-tax returns to 30th Sept 2019

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  1. RIDDHI SIDDHI says:

    #Its a very serious matte (Concerned authorities must look in to the matter urgently.)r#:
    How can an associations be a “Tax Bar Association” having “non Lawyer Professionals/Practitioners” as a member of such Bar Association. “State Bar Council” as well as “The Bar Council of India” must seriously look in to this type of formation of Bar association having “non Lawyer Professionals/Practitioners” as a member of such Bar Association.
    ONLY a Legal Professional having been enrolled himself/herself as a Member of State Bar Council can be a member of any Bar Association WHETHER FORMED as TAX BAR ASSOCIATION OR DISTRICT BAR ASSOCIATION.

  2. Rakesh Shukla says:

    We are working in private sector and for your information we have not sufficient staff to help us for finalize the accounts and done all type of work so more burden from each side. so consider our request and extend the due date.


    This happens every year. It is not known why Government not change the due date on permanent basis. All C.A face less stress of workload. What is fun to give the relaxation on very last moment, This can be announced earlier by the depatment.

  4. CA.Prabhakar.G says:

    Many of the independent practioners without troubling their exam going articles students, are opening their laptops and working themselves from 5 AM and closing the same at 12 AM. Because of the heavy rains daily power failures and battery backups are not sufficient . But compliances are too many for the same client demanding at the same time. For ex. ROC , TAX audit, GST etc.
    Don’t know what to do and what to skip.
    This is all due to lack of planning on the part of the concerned depts.

  5. Rajan Tijoriwala says:

    Tax audit due date should be extended by honourable F.M. to 30-11-2019 considering the workload involved & for doing quality work for clients as well as govt by CA’s who are toiling hard currently but still may not be able to complete Work by 30-09-2019.

  6. Mohd Shuaib says:

    Demand for extension of due date of tax audit is genuine. The whole process of tax audit including uploading of audit report , balance sheet and P/L and generation of UDIN etc is time consuming. Sufficient time must be given to discharge this function properly. The extension may please be announced well in advance to relieve those involved in the process from stress.

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