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SS / WMTPA / IT representation /18-19 /0918
20th. September 2018

Shri Arunji Jaitley,
Minister of Finance,
Union of India,
Now Delhi – 110 001

Sub: Extension of due date for filling ITR in respect of compulsory audit assessee

Dear Sir,

Our Association represents Tax Consultants, Advocates, Chartered Accountants, Company Secretaries & Cost Accountants practicing in direct & indirect taxes from Western Maharashtra Presently, we have around 1500 plus active members Our Association always represents the concerns and problems faced by these members before the respective tax authorities This initiative of our Association has proved beneficial for the tax administering authorities, our members and ultimately the tax payers at large The Income – Tax representation Committee is one of the important committees of this Association to represent to the Government. Central Board of Direct Taxes & other appropriate forums regarding various legislative amendments and issues concerning direct taxes It is the constant endeavor of this Committee to act as a bridge between the tax payers & tax authorities This representation is in respect of the problems faced by Income tax assessee & tax professionals We would like to submit the following point wise issues for your perusal

You are aware that the following compliances of clients are to be complied with by we tax professionals in the month of September

1) Tax audit reports u/s 44-AB of the Income-Tax Act 1961

2) Director KYC compliance.

3) GSTR-1, GSTR 3B on respective due dates,

4) GSTR-2A, downloading, reconciliation & difference to be pointed out to client for his follow-up or reversal of claimed set-off.

5) Clients accounts to be verified, closing adjustments to be done & final statement of accounts be drawn.

You are also aware that

1) The due date for non audit assessee was extended by 1 month from 31st July to 31st August.

2) Income-tax website was down on last week of August by which returns uploading was taking too much time.

3) Income-tax return filing utilities have been changed for no of times by your department.

4) Form of Tax audit report was changed

5) Utilities of Tax audit were changed.

6) Additional points have been added in tax audit report.

7) Some of the additional points of reporting added were kept in abeyance till 31.03.2019

8) 26-AS could not be generated from website properly

As per the existing provisions of Income-tax Act 1961, the duo dates for filing Income-tax returns are.

For non audit assesses 31st July
For Compulsory audit assesses 30th September

It is therefore clear that for getting the accounts audited & filing audit reports each of us is getting time span of 2 months after the due date of non audit assesses However, there are following additional hurdles in preparing 8 complying with the tax audit work. which are

1) GST website always gets crashed for 2-3 days before the prescribed due date of compliance 8 hence no of man hours are wasted in completing the task

2) Additional reporting in tax audit reports are prescribed from this year are first required to be understood be we professionals 8 then the data required is to be gathered from the respective Accountants 8 assessee

3) Keeping the changes in tax audit report partly in abeyance has also increased confusion.

Shri Sushilji Chandra,
The Chairman,
Central Board of Direct Taxes,
North Block Secretariat,
NEW DELHI — 110 001

Dear Sir.

You are requested to consider the above & do the needful in the matter in the interest of tax payers, tax professionals & the Income tax department also

For The Western Maharashtra Tax Practitioners Association

(Santosh S Sharma, Chairman Income Tax representation Committee)

(Manoj Shar Chitalikar, Convener, Income Tax representation Committee)

(Navneetlal A. Bora, President)

Checkout the role of Section 44AD : Presumptive taxation here

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