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Nagpur Chamber of Commerce Limited made a Request for Extension of due date for filing of Tax Audit reports, Transfer Pricing Audits and Income-tax returns-AY 2020-21 till 31st March 2021.


73, Central Avenue, Seva Sadan Square, Nagpur-440018. Ph. : 2720164 Email :


1) Smt. 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,
North Block,
New Delhi-110001

Sub.: Request for Extension of due date for filing of Tax Audit reports, Transfer Pricing Audits and Income-tax returns-AY 2020-21 till 31st March 2021.

Hon’ble Madam/Sir,

Our Chamber, Nagpur Chamber of Commerce Limited, was formed almost 70 yrs back and is one of the oldest organization of the traders & business fraternity not only of Nagpur but of entire Vidarbha Region. The Chamber is member of FICCI and serving to almost 5000 traders & business entities.

We would like to address the concern of the members, being business & traders fraternity 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 31st March 2021.

As you are aware that all assessees who are liable to audit either under Income Tax Act, 1961 or under any other law for the time being in force are required to file their return of income by 30th November of the Assessment year 2020-21.

The business/traders are also supposed to file tax audit report by 31st October, 2020.

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

The Covid-19 Pandemic

At the outset, we commend the Government for efficient tackling of the pandemic using lockdown and staggered unlock as a tool. We also appreciate that the government suo motu provided extension for tax audit and income tax return filing up to 31st October, 2020 and 30th November, 2020 respectively.

The country is being unlocked gradually and as your goodself may be aware that the spread and severity of the Corona virus has just started to decline. Amidst this, several restrictions are still in place in the States and movement is still restricted. Commuting via public buses and/or other public transport is restricted and not fully operational. Given the increasing numbers of reported cases of COVID-19 there is a fear among the people of getting infected due to which they prefer not travelling at all or restrict it to the vicinity of their homes for their necessity. Due to this, several business units, industries and private offices have still not resumed functioning at all or fully. This also includes the offices of the Chartered Accountants, their staff and audit assistants.

Even, Honible PM in his address to the nation yesterday i.e. on 20th October 2020 specifically stated that the war against Covid is still going on. The number of cases are decreasing but the same is not over, the public should still continue to take utmost care and follow the self imposed restrictions.

Due to this, the details required for carrying on tax audit and filing the return of income are not being compiled and send promptly and thus there are hurdles in completion of audits. Also travelling to the place of audit by the Chartered Accountants and their staff are very difficult or travel by the traders/business person’s staff to the office of Chartered Accountants are also very difficult.

Several Chartered Accountants and Tax Practitioners themselves have also been infected and have not been able to work for minimum of 21 days. Also, visiting any audit place exposes them to the virus making them prone infection. Further, the senior citizens including senior professionals and senior assessees are advised to stay at home

These hindrances are making it very difficult for the assessees, the Chartered Accountants and the Tax Practitioners to comply with even the extended due dates.

Release of utility for Revised Form 3CD (Tax Audit Report)

On 01st October 2020 vide notification there is revision in form 3CD i.e. tax Audit for which the revised schema / utility is not yet released, this is creating a situation of confusion and unrest among the business & Trade fraternity.

Extension of due date for assessment year 2019-20

Recently, on the 30th day of September, 2020 the CBDT has extended the date for filing belated and revised return of income for Assessment Year 2019-20. Date was extended from 30th September, 2020 to 30th November, 2020, that too suo motu. We appreciate the step taken by CBDT in the interest of taxpayer community.

Extension of last date of AGM

Ministry of Company Affairs has extended the last date of holding AGM for corporates to 31st December,2020 only due to pandemic. Based on this, the statutory audit can be concluded even beyond 30th November, 2020.

Madam, you may please note that the tax audit can be conducted only post completion of statutory audit, post which only the income tax return can be filed by the Company. In a case where the Transfer Pricing audit is also applicable, the return shall be filed only after the filing of Transfer Pricing Report in Form No. 3CEB. Therefore, complying with the tax audit and Transfer Pricing Report due date of 31st October, 2020, and return filing due date of 30th November, 2020 seems very improbable.

Our Chamber 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. Also we are rather confident that the Government will suo moto extend the dates and that too well before last date.

We would be thankful if your goodself judiciously extend the date well in advance which will keep the trade fraternity as well as professionals relieved from stress and movement in this current pandemic situation and would be effective and meaningful.


For Nagpur Chamber of Commerce Limited

Vishnu Kumar Pacheriwala

CA. Kailash Jogani
Immediate Past President

Cc. : The Hon’ble Prime Minister’s Office, New Delhi

Download Representation in PDF Format

Also Read Other Similar Representations:-

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  1. mukesh says:

    Namaste ~ i am freelance accountant and express the following in common interest of all ~
    Post March 2020 every sector is going through the roller coaster ride. Even now the lock down is lifted but there are many unseen lockdowns that are still existing. Life is not normal as it was. Everyone has own challenges to solve. And this is universal. in heart of our heart each one of us know this. Even Government has its own challenges on its platform. But leaving all this apart form individual reasons and challenges, in the interest of Humanity i feel it is reasonable to provide relief, for all of us know that time is healer.
    In the Light of above it is requested that all the deadlines for the FY, whatever it may be, be extended to 31.03.2020. And this should come as a gesture of goodwill for one n all. We should respect the same and abide by. For it will be responsibility of each one of us and not of any individual or organisation, association or institution.
    I feel this is very reasonable looking at situations around us. Let us walk the path together, for each one of us is still very fresh to the experience of Covid19 pandemic.
    Hope this request will be accepted as hunbly as it is presented.

  2. PANCHSHEEL says:

    Nirmala ji is busy distributing covid vaccine in Bihar. I have not seen such a ruthless and arrogant finance minister in history. God save CAs and poor accountants



  4. SUNIL BEHL says:

    It’s a genuine demand and it is humanly impossible to complete the audit/ itr within the current due dates. In my opinion, in the given circumstances, there should not be any need for anyone to beg for it. THE GOVERNMENT MUST DO IT SUO MOTO. In such serious situation, I don’t know why ICAI / FICCI/ CII etc. are not taking up this cause to get the due date extended for TAR/ ITR to 31st March,2021 for every assessee.

  5. P.K.KUNDU, ADVOCATE says:

    Why the finance ministry waiting for last date; they should immediate extend the date of all returns and audits. All the professional are in will create the health problems also. Due date must be extended till 31st March,2021 indeed.

  6. Bhausaheb shivaji supekar says:

    We also facing similar issues for file tax audit and it filing, as per the request, please extend the due date to 31st March, 2021, as suggested.

  7. Tejas Laliwala says:

    Inspite of so many representations made by various CA fraternity and tax and other professionals of various states, why is Hon. Finance Minister still not extending the date of filing tax audit reports?
    The due date of 31 October 2020 is very unreasonable for tax audit reports to be filed, considering the fact of Covid 19 situation is still present and everyone – clients, business houses, professionals and general public at large are largely affected by this pandemic. Also, the due date for conducting AGM and therefore for completing statutory audits is extended to 31 December 2020 very much in advance by the MCA to avoid confusion, chaos, pressure and tension, so why due date for tax audits is not yet extended?
    The statutory audits should get finalized first and then the tax audits. Now, as the last date for conducting AGM is extended to 31 December 2020 and therefore the due date for completing statutory audits is extended, as such, how can the due date for tax audits be 31 October 2020? This means that the clients have to first close the books of account, get the statutory audit completed and also the tax audits on or before 31 October 2020. So, the entities and clients to whom tax audit is applicable it does not make sense to extent AGM to 31 December 2020.
    Not extending the impracticable due date of 31 October 2020 for filing tax audits until 22 October 2020 shows inefficiency on the part of FM to make timely decisions and announcements.

  8. CA BASHIR A R says:

    Due to COVID-19 Govt is insisting to maintain social distances and in such situations how to complete GST & Tax Audit work as number of times client and accountants attendance is reqd for explaining the issues how it is possible to work and complete the compliances within due date??

  9. Stan Alvares says:

    It would be helpful to extend the date because all experienced CAs and accounting personnel have been working from home since their age is in the COVID band. Residential societies have even barred visitors to CAs till recently. So many people including me have had to share their laptop with their family for online classes even if we have two more laptops in warranty as nearby service centers have closed down and others have a huge backlog and are frighteningly congested with visitors. So it’s a very complex situation which needs careful attention and reddressal.

  10. Unnikrishnan says:

    Why all are so worried , if you are given an impossible target dont comply ,Let us see who is bold enough to charge the penalty. We have courts for that .So smile and relax

  11. P.T.SWAMY says:

    In this situation of COVID-19, I requested Hon’ble Finance Minister to extend the due date of filing of reports in connection with Income Tax.

  12. Ghanshyam says:

    Due to this Corona every kind of activity on the earth is derailed,children not going to school, exams for last year and current year is postponed or general permotuo is allowed, doctors are only consantrated on covid patients others are neglected yet, business activities are badly affected,how only audits and tax returns can be timely furnished, hence request for extension of time is on valid grounds and authorities and ministry of finance should allow the extension.

  13. ANiL VERMA says:

    I am sure government under Ministry of Finance and CBDT are well aware about the kind of stress suffering by CA, tax professionals, Assesses due to pandemic situation, ministry has requested to extend due dates sue moto without waiting for last date, no doubt compliance has importance to be done with, however life is more important rather than compliance under under the law for the time being in force..
    It is earnestly requested to extend the due dates well in advance. CMA ANIL B VERMA. CHAIRMAN Nagpur Chaper of Cost Accountants

  14. Balaji says:

    A suggestion – Instead of extending the date for the last FY multiple times, is there a provision to file last FY and current FY together by July 2021? That way we can ease the load on people and auditors. Not sure if it is a viable option, but just my two cents.

  15. SURESH MEHTA says:

    Sir,we are not able to attend office due to carona .till date only 3 percent tax audit are done as many clients have yet not resumed operations . Govt must extend the duedate.

  16. Raghu k says:

    Dear madam, as senior citizens can’t come out of their houses due to Corona virus so please postpone the tax filing date to 2021 march 31. Thank you

  17. M v mohan rao says:

    Please extend the date for submission of returns till 31 March 2021. Lot of work needs to be done. Many staff are infected and offices closed for many months. Travel by bus auto rickshaw and trains not possible too.
    Thank you,
    M V Mohan Rao

  18. MAL CHAND Garg says:

    Why the finance ministry waiting for last date; they should immediate extend the date of all returns and audits. All the professional are in will create the health problems also.

  19. Isha says:

    Pls extend due date due to non availability of train transport, our staff can not come to office. From Kalyan to CST it will take ८ hours in travelling.heavy traffic etc
    Also CA staff is also less in quantity.. so please don’t wait for declare due date extension till midnight of ३१St Oct. Work load is pressuring us. Pls declare it aeap to release the tension.

  20. Azhar says:

    Please extend the date as in bangalore still cases increasing shops and traders are facing lot of problems shops fully not opened. So many establishment in thickly populated areas, locals are not permitting outsider to area due to pandamic we are facing a lot of problems. Please extend the date tomorrow so that we can plan for the assesses for audit work

  21. JANARDHANA RAO K says:


  22. ronak says:

    Why we need to bag for extention if for Service tax for 2014.15 they use extended period and sending notice to all as drive with extended time periods of six month due to pandemic now it become custom that after putting mental stress they exrend on last day and enjoy POWER given by us and not extending and waiting for all to beg for extention and then extends its very painful for those who is compliant citizen. THEY KEEP US ENGAGED IN PETTY ISSUE. WE ARE MANGO PEOPLE.

  23. Pradeep kumar says:

    please consider the mental situation of a mass of staff who are working day and night to fulfill the filing requirements fixed by Govt . They do not have any facility to commute between offices to complete Audit. Not Enough medi care if they fall with corona etc .Personally I too in the same situation.Please keep away from victimize the poor

  24. Muralitharan RC says:

    We also facing similar issues for file tax audit and it filing, as per the request, please extend the due date to 31st March, 2021, as suggested.

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