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Direct Taxes Professionals’ Association made a Representation to FM for extending the due dates of compliance under Income Tax Act , the Companies Act and CGST Act and widening the scope of benefit in case of cases where Assessee has been allowed relief by Hon’ble ITAT and due date of filing appeal by Department has expired.


Income Tax Building, 3, Govt. Place West, Ground Floor, Kolkata 700001 Ph – 033-22420638

 Ref. No.- DTPA/Rep/20-21/16

Dated 23rd December, 2020


Mrs. Nirmala Sitharaman,
Hon’ble Finance Minister,
Ministry of Finance,
Government of India,
North Block, New Delhi 110 001

Respected Madam,

Sub: Representation for extending the due dates of compliance under Income Tax Act , the Companies Act and CGST Act and widening the scope of benefit in case of cases where Assessee has been allowed relief by Hon’ble ITAT and due date of filing appeal by Department has expired

Established in the year 1982 and with the present strength of over 1725 members comprising of Chartered Accountants, Advocates & Tax Practioners, we “DIRECT TAXES PROFESSIONALS’ ASSOCIATION” feel great pleasure in introducing ourselves as one of the premier professional Association in Kolkata. We have been organizing seminars and conferences on topics of professional interest and have also been sending representations to the Government on various economic and taxation issues from time to time.

First of all we wish to thank you for fully appreciating the problems faced by Trade, Commerce and Industry and allowing necessary extensions in all matters since the announcement of Lockdown 1.0

Request for extension in due dates of compliances:      

Respected Madam, we wish to appraise your good self that in spite of best possible efforts on the part of Professionals and Business entities, with limited staff and resources as well as safe mobility, the work of GST Audits of 2018-19 , Audit of Accounts for the year ended 31st March 2020 , Tax Audits under section 44AB  and filing of Income Tax Returns for A Y 2020-21 has not been completed. You will further appreciate that West Bengal, still continues to be third worst suffering state till date after Kerala and Maharashtra and therefore perfect normalcy in operations is yet to set in.

In so far as Companies cases are concerned, their due date of holding AGM had been allowed 3 months extension by MCA and therefore almost all companies are likely to hold AGM by 31st December 2020, their Audits are not completed in many a cases and since a copy of the audited report is also attached with the Tax Audit Report, it in nearly impossible to complete the furnishing of Tax Audit Report. The Form 3CD for Tax Audit Report under sec. 44AB as well as Form 3CEB for Report in case of International and specified domestic transactions under sec. 92E have also been recently modified vide Notification No.82/2020 dated 1.10.2020.

Respected Madam in view of the aforesaid situation, we humbly request to extend the due dates for all the following compliances be extended to at least 28th February 2021-

1. Holding of Annual General Meeting for Companies- the extension of 3 months be further extended by two months

2. Tax Audit Report under section 44AB and Report under section 92E of the Income Tax Act 1961

3. Filing of Income Tax Returns by all assesses for A Y 2020-21 .

4. Vivad Se Vishwas declarations under the ongoing scheme

We further request that the date for GST Audit Report for 2018-19 & 2019-20 in GSTR 9 , 9A and 9C be kindly extended to 31st March 2021.

Since the specified date and due date are approaching soon, we would appreciate if your good self would could make an early announcement in this matter so that the entrepreneurs and professionals do not unnecessarily expose themselves to too much stress and risk of Pandemic.

Request for enabling assesses to opt for Vivad Se Vishwas Scheme for cases where they have been allowed relief by Hon’ble ITAT and due date filing appeal by Revenue has expired :

In many cases where Assessee has been allowed relief in appeal before   CIT (A) or before ITAT but the   Assessee for peace of mind wants to file declaration   under Vivad se Vishwas Scheme if department has preferred an  appeal or may prefer an appeal. The Assessee in such cases does not know the appeal number because he is not aware as to whether any appeal has at all been filed and the time limit for filing appeal has already expired. In such cases by an answer to a similar question no 67 of  CBDT circular no 21/2020 dated 4th December 2020 it was mentioned that –

Whether in cases where the appellate authority has quashed the prosecution complaint or ruled in favour of taxpayer and no further appeal is. filed by Department on or before. filing of declaration are eligible?

Yes, such cases are eligible if the time limit for filing appeal by the Department has expired and the Department has not filed appeal (with or without condonation of application

However while filling up the declaration Form No. 1 is not being accepted in the system without appeal ref no .

We therefore request you to please modify the utility so that such declarations are accepted even without filling up such detail of appeal
by the department whether filed or may be filed.

Request for enabling extending CLSS Scheme of the MCA :

Madam, the CLSS Scheme to submit forms without additional fees was allowed extension till 31st December but the entities and stakeholders have not been able to make proper intended use of the same as they could not prepare their pending papers and in many cases pending matters with NCLT are also being taken up very slow. Therefore, it is requested that the said scheme is also extended to 31st March 2021.

Thanking You and Assuring you of our full co-operation,

Yours faithfully,


CA N.K. Goyal

Adv Narayan Jain
Representation Committee

CC To:

1 Sri Anurag Singh Thakur

The Hon’ble Minster of State For Finance

2. Sri Ajay Bhushan Pandey

Revenue Secretary, Ministry of Finance

3 Shri P.C. Mody,


Central Board of Direct Taxes,

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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