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Tax Bar Association, Jodhpur has made a representation to Smt. Nirmala Sitharaman, Hon’ble Union Minister of Finance & Corporate Affairs & 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. Text of the representation is as follows:-

Dated: 10/10/2020


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

3) Prime Minister Office New Delhi

4) Shri Gajendera Singh Shekhawat Hon’ble Cabinet Minister

Hon’ble Madam,

Greetings of the Day!

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.

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 direct 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 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 and tax audit report by 30thNovember of the Assessment year 2020-21.

The assessees 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 not yet started to decline and instead is rising each day. Amidst this, several restrictions are still in place in various 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 industries and private offices have still not resumed functioning at all or fully. This also includes the offices of the Chartered Accountants and Tax Practitioners.

Due to this, 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. Also travelling to the place of audit is very difficult for the professionals and their staff.

Several Chartered Accountants and Tax Practitioners themselves have also been infected and have not been able to work for minimum of 14 days. Also, visiting any audit place all them or 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.

Extension of due date for assessment year 2019-20

Recently, on the 30 th day of Septemeber , 2020 the CBDT has extended the date for filing belated and revised return of income for Assessment Year 2019-20 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 31stDecember,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.

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 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 professionals and the assessees relieved from stress and movement in this current pandemic situation and would be effective and meaningful.

Yours Faithfully,

A Definite Partner in Nation Building

Tax Bar Association, Jodhpur

CA. Vishnu Prakash Daga

CA. Manoj Gupta
Joint Secretary


CA. Raj Bothra

Download Representation in PDF Format

Also Read Other Similar Representations:-

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  1. Jini says:

    Request your Honour to grant extensions on due dates of transfer pricing and tax audits as well as income tax returns at the earliest possible as there has there has been lot of struggle for both tax payers and consultants to comply with the upcoming deadlines with office closures and limited connectivity. Covid times have already been difficult phase for everyone us. With delay in theses extensions or no extensions is rather adding on.

    Further, as Financials of even many multinational companies are yet to finalised because of extensions in AGM, sigining off transfer pricing report without signed financials would not be rather an acceptable approach.

    Hoping to be heard

  2. Rajat B says:

    Now that the CA exams are postponed, avaiability of Trained staff has become difficult. These are the people who have done bulk of the work last year and trusting anyone else to take it up fresh will be difficult. Extend due date till 31st March for all assesses other than salary. Salary Returns and non audit cases can be January 31st.

  3. akshay batavia says:

    Date should be extended up to June 2021 for the accounting year 2018-2019 & 2019-2020. Some city local train & buses are not running. Still corona cases are increasing. Still people are worries to going out. So many charged accounted ,accounted & practicener getting infected. Business are very vulnerable. People are struggling to survive. Govt should be allowed to filling 2 years returns at the time of filling accounting year 2021- 2022. 2021-2022 are the worst year for the most of businesses men. Taking home also very difficult for a common people. Banks are asking so many papers. Genuine people are worst effected to getting loan from bank. Govt should be also clear regarding capital gains tax from a property sale. Govt should be make more good planning to help people from getting out of this type crises.

  4. Senthil 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.

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