CA. Nilesh S. Vikamsey
THE INSTITUTE OF CHARTERED ACCOUNTANTS OF INDIA
(Set up by an Act of Parliament)
23rd October, 2017
Shri Arun Jaitley,
Hon’ble Finance Minister,
Ministry of Finance,
Government of India,
New Delhi -110 001.
Sub: Request to extend the due date of filing Income-tax returns for assessees mentioned under clause (a) of Explanation 2 to Section 139(1) and Tax Audit report u/s 44AB for the AY 2017-18 from 31st October, 2017 to 30th November, 2017
At the outset, we thank you for accepting our suggestion for extending the ‘due-date’ for filing Income Tax Returns and various reports of audit from 30th September, 2017 to 31st October, 2017 vide our representation No. ICAI/DTC/2017-18/Rep-24, dated 29.8.2017 (copy attached). The said extension was made so as to allow sufficient time to the assessees’ and tax professionals, who are required to make first time compliances in view of the fact that the Goods and Services Tax (‘GST’) has come into effect on 1-7-2017.
In this regard, we wish to inform you that members and assessees are still grappling with the complexities of first time GST compliance and the first time compliances required to be made due to implementation of Income Computation and Disclosure Standards (ICDSs) as stated below:
1. First time GST compliance :
The various compliances which are required to be made in the months of October and November due to the newly enacted GST law are given in the following table:
|Return||Tax period||Due Date|
|GSTR-6||July, 2017||13th Oct,2017|
|GSTR-4||July-September 2017||18th Oct,2017|
|GSTR 3B||September, 2017||20th Oct,2017|
|GSTR-2||July, 2017||31st Oct,2017|
|Form TRANS 1||July, 2017||31st Oct,2017|
|GSTR-3||July, 2017||10th Nov,2017|
|GSTR 3B||October, 2017||20th Nov,2017|
Further, as per press release dated 6th October, 2017 the last date for filing the FORM GSTR-4 return under composition scheme for the quarter July-September, 2017 has been extended to 15.11.2017. Also, the last date for filing the return in FORM GSTR-6 return by an input service distributor for the months of July, August and September, 2017 has been extended to 15.11.2017.
The filing of such GST returns is being done for the first time. The GST law is new and hardly any lime has been given after enactment to absorb, assimilate and implement the new law, it is consuming a lot of time of the members in comprehending and ensuring compliance with the new law. Also, the technology issues has resulted in loss of innumerable man hours of assesses and professionals impacting all other work.
2. First time reporting requirements due to applicability of newly notified Income Computation and Disclosure Standards (ICDSs).
The amended From No 3CD has substituted sub-clause (d) of clause 13 with new sub-clauses (d), (e) and (f) requiring reporting of the adjustments and disclosures mandated as per the newly notified Income Computation and Disclosure Standards (ICDSs). In addition to this, reporting the net effect on the income due to application of ICDS has to be done for the first time in the ITR forms notified tor the AY 2017-18 under ‘Schedule ICDS – Effect of Income Computation Disclosure Standards on profit’.
As the reporting in respect of ICDS in Form No. 3CD and ITR Forms is being done for the first time, there are lot of nuances or the new reporting requirements imposed due to implementation of ICDSs. As a result, members and assessees require some more time for the said reporting.
In view of the above, our members are voicing their apprehensions regarding the limitations of time available for conducting tax audit and filing Returns of Income by October 31, 2017 for AY 2017-18.
Institute believes that the members of the profession have to continuously maintain and strive to enhance the standard of services provided by them, which includes the quality of audit conducted by them. Conducting the tax audit in an effective manner is therefore necessary to ensure that there is no loss to the Revenue. In view of above and our earlier submissions made vide the attached representation, it is once again requested that the last date of completion of tax audit and filing of tax audit report and income-tax returns, which has been extended to October 31, 2017 may be further extended to November 30, 2017.
(CA. Nilesh S.Vikamsey)
End: As above