Tax Practitioner’s Association, Indore has made a Request for Extension of Due Dates for filing Tax Audit, Audit Reports under Income Tax Act and ITR for Assessment Year 2020-21. it has requested that due date for Tax Audit/TP Audit and Income Tax Return (Non Audit) be extended to 28th February 2021 and due date for Income Tax Return (Audit Case) be extended to 31st March 2021.

Relevant Text of their representation to Smt. Nirmala Sitharaman, The Hon’ble Union Finance Minister, Government of India, North Block, New Delhi is as follows- 

12th Dec , 2020

Smt. Nirmala Sitharaman,
Ministry of Finance,
North Block, New Delhi 110 001.

Hon’ble Madam,

Sub: Request for Extension of Due Dates for filing Tax Audit, Audit Reports under Income Tax Act and ITR for Assessment Year 2020-21.

Tax Practitioners Association (TPA), Indore having Advocates, CAs, CS and Tax Practitioners as its members with over 550 members. The TPA regularly takes up initiatives to act as a bridge between stakeholders and concerned regulatory bodies in order to convey and help in resolving genuine grievances or effectively implement the laws.

Today, we have come forward with a request of extending the due dates of Tax Audit, Transfer Pricing Audit, various other Audit Reports under Income Tax Act and Income Tax Return filing for AY 2020-21.

Apart from others, this request is based on following major reasons being:

The Covid-19 Pandemic, Night Curfew and its effect on professional work:

1. At the outset, we appreciate the earlier extension provided for tax audit and income tax return filing up to December 31, 2020 due to continuing pandemic of Covid -19. The spread and severity of the Corona virus has not been reduced and instead it is rising each day, Night curfew continue, Restriction on Keeping offices open etc. impacting adversely in conducting audit and preparing tax returns. Commuting via public buses/trains and/or other public transport is restricted and not fully operational.

Due to this, several industries and private offices have still not resumed functioning at all. This also includes the offices of the Tax Advocates, CA’s , Tax Practitioners etc. resulting the details required for carrying on tax audit and filing the return of income are not being received promptly and thus the audits cannot be efficiently performed. Further also travelling to the place of audit is very difficult for the professionals and their staff.

Several our members have also been infected and have not been able to work for minimum of 14 days which extends to a month due to post Covid-19 health recovery. Also, visiting any audit place exposes them to the virus making them prone infection. Further, the senior citizens including senior aged professionals  and senior aged assessee are advised to stay at home. These hindrance are making it very difficult for the assessee, the Tax Advocates, CAs and the Tax Practitioners to comply with the presently extended due dates. We would like to appreciate that for the very same reasons that we have cited above, i.e. genuine difficulties being faced by the taxpayers due to outbreak of COVID-19 pandemic, Night Curfew the CBDT has earlier extended the date for filing Tax audit and income tax return filing up to 31st December, 2020 and 31st Jan., 2021 respectively, but the underlying reason of COVID-19 still continuing more vigorously.

2. Delay in release of return filing software utilities: The utilities for the income tax return were made available only June’20 onwards instead of April’20 and latest on updated during first week Dec., 2020. Usually, the income tax returns are notified in the month of April, but due to the pandemic, the release of the returns also have been delayed on an average by 4 to 5 months. We are submitting the summery return wise as under:

SI.No. Income Tax Return form Schema Release Date Schema Updation Date Utility Updation date
1 ITR 1 June 2, 2020 September 9, 2020 December 1, 2020
2 ITR 2 June 26, 2020 November 4, 2020 December 3, 2020
3 ITR 3 July 31, 2020 November 9, 2020 December 1, 2020
4 ITR 4 June 5, 2020 October 15, 2020 December 1, 2020
5 ITR 5 August 25, 2020 November 18, 2020 December 3, 2020
6 ITR 6 September 22, 2020 November 22, 2020 December 3, 2020
7 ITR 7 September 3, 2020 December 8, 2020 December 8, 2020
8 3CA-3CD November 4, 2020
9 3CEB November 4, 2020

Although the utilities were released as on the above mentioned dates, the 700+ paged Instructions for filing the return of income were released only on October 23, 2020. These instructions were further revised on November 25, 2020 i.e. just a month before the due date of filing of income tax return, not giving the professionals and assesses enough time to even take a note of the most important points.

These are indeed unusual times and when the dates were last extended one had expected a reasonable resumption of activities — however the second predicted phase of COVID spread resulted in a slow unlock down compared to what was expected and hence the earlier date of December end which seemed reasonable at one time is now looking like an impossibility.

REQUEST: With due respect to the above difficulties faced by the assessee and the professionals, we request your Honour to take them into consideration and extend  the due dates for tax audit, transfer pricing audit and other audit reports under income tax act as under:

Returns /Audit Reports Present Due Dates Requested Due Dates
Tax Audit/TP Audit 31st Dec., 2020 28th Feb, 2021
Income Tax Return (Audit Case) 31st Jan, 2021 31st March, 2021
Income Tax Return (Non Audit) 31st Dec., 2020 28th Feb, 2021

The entire fraternity of taxpayer and professionals will highly appreciate if this is done soon enough (i.e. well in advance) to allow them to get a clarity to. We look forward for your kind consideration to the genuine request.


Yours Sincerely,

For Tax Practitioner’s Association, Indore

(CA Manoj Gupta)

(CA J P Saraf)
Hon. Secretary

CC: Chairman CBDT, New Delhi.

Download Representation in PDF Format

Also Read:-

S. No. Date Association Particulars with link
1 9 Dec 2020 Western Maharashtra Tax Practitioners Extend due dates of Tax Audit & ITR for AY 2020–21
2 12 Dec 2020 Gujarat Sales Tax Bar Extend GSTR-9/9A/9C due date for FY 2019-20 to 30/06/2021
3 12 Dec 2020 Chamber of Tax Consultants Extend due dates for Tax/Transfer Pricing Audit & ITR for AY 2020-21
4 12 Dec 2020 Tax Practitioner’s Association, Indore Extend due dates for filing Tax/TP Audit Report & ITR for AY 2020-21
5 14 Dec 2020 AGFTC, ITBC and CAA Extend due dates of Tax Audit Reports/ITR for A.Y. 2020-21
6 15 Dec 2020 BCAS, CAA (Ahmedabad), CAA (Surat), KSCAA & LCAS Request to Extend Due dates under GST & Income Tax
7 15 Dec 2020 Tax Bar Association, Bhilwara Request to extend Due Date of filing of Tax Audit & ITR
8 15 Dec 2020 Direct Taxes Professionals’ Association, Kolkata Extend due date of ITR & Tax Audit for AY 2020-21
9 16 Dec 2020 Lucknow CA Tax Practioners’ Association Extend Due date for filing Tax Audit Report & ITR
10 16 Dec 2020 Jamshedpur Chartered Accountants Extend Due Date of filing Tax Audit & ITR to 31.03.2021
11 13 Dec 2020 Direct Taxes Committee of ICAI ICAI requests for extension of various Income-tax due dates
12 10 Dec 2020 Udaipur Tax Bar Association Further extend due dates of ITR & Tax Audit Reports for FY 2019-20
13 15 Dec 2020 CA Social Affiliation (CASA) Extend Tax/TP Audit Report & ITR filing due date for AY 2020-21
14 19 Dec 2020 Chartered Accountants Association, Jalandhar Extend Due Dates for Tax Audit and Income Tax Return Filing
15 19 Dec 2020 All India Federation of Tax Practitioners (CZ) Request for extension of due dates of Tax Audit Reports/ITR
16 19 Dec 2020 Vyyapaar Mandal Association, Nagore & AIMTPA Extended Income Tax & GST Audit/Return/Compliance dates
17 17 Dec 2020 Emerging Businesses Chamber Of Commerce Extend due dates for Income Tax Audit & Returns for AY 2020-21
18 Dec 2020 The Uttar Pradesh Tax Bar Association Representation for Extension of time for Tax Audit & Return
19 19 Dec 2020 Tax Bar Association, Guwahati Extend Tax Audit/ITR due dates for AY 2020-21
20 21 Dec 2020 Tax Bar Association, Guwahati Extend due dates of GSTR-9/ GSTR-9C for FY 2018-19 & 2019-20
21 17 Dec 2020 Karnataka State Chartered Accountants Association Waive Late Fees for Delayed Filing of GST Returns
22 15 Dec 2020 Direct Taxes Professionals’ Association Extend Vivad Se Vishwas Scheme due date to 15.03.2021
23 15 Dec 2020 Direct Taxes Professionals’ Association Extend due date of AGM to 31st March 2021
24 15 Dec 2020 Association of Tax payers & Professional, Agra Extend due of GSTR-9, GSTR-9A & GSTR-9C
25 08 Dec 2020 Tax Bar Association (Regd), Allahabad Extend due date of ITR/Tax Audit/GSTR-9/GSTR-9C
26 08 Dec 2020 Tax Consultant & Practitioners Association of Kerala Extend due of ITR, GSTR 9, 9A & 9C for FY 2018-19 & 2019-20
27 21 Dec 2020 Tax Bar Association, Guwahati Extend CFSS 2020 & LLP Settlement Scheme 2020 to 31.03.2021
28 22 Dec 2020 Income Tax Bar Association, Lucknow Extend Time for filing ITR & Audit Report for A.Y 2020-21
28 22 Dec 2020 53 GST and Trade Associations 53 Associations requests Extension for GSTR 9, 9A & 9C
29 16 Dec 2020 Chandigarh Chartered Accountants Taxation Association Extend Income Tax & GST Return & Audit due dates
30 22 Dec 2020 Bhayander CA Social Group Request to extend Due date of Annual GST Return & Audit
31 22 Dec 2020 Luminaires Accessories Components Manufacturers Association Extend due dates for Tax Audit & Income Tax Return filing for AY 2020-21
32 22 Dec 2020 All Professionals, Tax Payers and Stakeholders Open letter for extension of Due dates under Income Tax and GST
33 22 Dec 2020 Punjab Accountants Association Extend due date for filing ITR & Tax Audit Report- AY 2020-21
34 22 Dec 2020 Bhayander CA Social Group Extend Income Tax Audit & ITR Due dates for AY 2020-21
35 23 Dec 2020 The Tax Bar Association, Odisha Extend due dates of Audit Reports, ITRs, GST Returns, VSV Scheme
36 21 Dec 2020 Sales Tax Bar Association, Delhi Extend Tax/TP Audit & ITR Due dates for AY 2020-21
37 23 Dec 2020 Direct Taxes Professionals’ Association Extend Income Tax, Companies & CGST Act compliance due dates
38 24 Dec 2020 ICSI Extend due dates of CFSS, LLPSS, Charge Forms, Meetings
39 24 Dec 2020 All Odisha Tax Advocates Association Extend due date for filing TAR/ITR/GSTR9/9A/9C
40 25 Dec 2020 BJP Economic Cell, Rajasthan Extend Income Tax, GST, LLP, Company Law due dates
41 23 Dec 2020 Hyderabad Chartered Accountants’ Society Extend Due date under GST and Income Tax
42 22 Dec 2020 A. P. Tax Bar Association, Vijayawada Extend date of filing of GSTR 9, GSTR 9C and IT returns
43 03 Jan 2021 National Company Law Tribunal Bar Association Representation for further extension of CFSS 2020
44 25 Nov 2020 Merchants Chamber of Uttar Pradesh Request for extension of Company Fresh Start Scheme 2020
45 04 Jan 2021 Adv. Anuj Bhatt Request to President to take Suo-Moto cognizance of GST Issues
46 03 Jan 2021 The Chamber of Tax Consultants Extend Income-tax due dates with humane approach
47 01 Jan 2021 WMTPA Highly Disappointing GST Audit Due Date Extension
48 01 Jan 2021 The A.P. Tax Bar Association, Vijayawada Extend due date of Form GSTR 9 and 9C for year 2018-19

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  1. SP says:

    All the due dates should be extend for at least 2 months because:
    The working is still not normal, COVID Positive Cases are increasing in the winters.
    Please consider the fact that due to the pandemic, Courts/ Educational Institutes/ Travel Modes are still not working.
    Even Parliament sessions are being postponed.
    Many employees are working from home just to finish the bare minimum required activities.
    CA Articles Staff have not resumed as they are staying at their home towns.
    Therefore, humble request to kindly consider the genuine demand of extension of all the due dates of Tax Audit, ITR, ROC, GST etc.

  2. NAVANEESH says:

    Respected Madam, We have lot companies to file so please extend the filing timing , due to covid employees are not able to come to office , it my personal request please extend the date , Thank you

  3. rajinder sharma says:

    Income tax return filing date should be extended to 28.02.2021 as all the public transport is not available/working due to blockade of roads from Delhi to other states and vice versa…….Rajinder sharma



  5. Mohammed Faishal says:

    Dear Madam Kindly extend the Date as In Bangalore Cases is Increasing and since Form one week all Buses are fully not Facing lot of problems extend Due Date for tax audit and Income tax

  6. Ca vimalchand jain says:

    Due to late conduct of ca exams the article staff has now started attending our offices. For want of staff we could not start audit work at the required speed. Even the I tax return filing is just 35%.we hope to complete audit and I tax work by Feb end only .

  7. Rajendra Karia says:

    IT returns filing dates must be extended as Tax Professional as well as clients are yet to normalise their office and work. Yet issues of staff and self travelling to office, particularly in metro cities is not restored. Most offices are working with less than 50% of its capacity. Impossible for Tax Professional as well as clients to comply in time in this once in a lifetime panadanic of Covid. Government support is the least we expect.

  8. Advocate pradeep khandelwal says:

    I also agreed this demand. Due date should ne extend due to situation of corona. This demand for all over India ( all states)

  9. VINOD K PUNJ says:

    The government should not be in a hurry in anything except in controlling and dealing with the pandemic COVID 19.
    They must avoid bringing in new controversial bills and acts in times of grave crisis. Otherwise, unnecessary mass human migrations will would paralyze the government efforts and management of pandemic, as in the case of ongoing agitation of farmers. The government will not lose anything even if they don’t construct a new building for Parliament or if they repeal the farm laws. We will need a Parliament House only if a population survives. The foremost concern should be to deal with health hazards, so potentially, present in our surroundings.
    Believe in whatever form of God you trust, but slow down all other activities including construction of Temples, Mosques, Churches, Gurudwaras, and so on, without any prejudices of any kind.
    Jai Hind, Jai Vishwa !

  10. PN Badri says:

    Very good suggestion and government should reconsider the due date due to pandemic crisis and especially in the interest of senior/super senior citizens health issues.

  11. BALWINDER RAVI says:


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