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CA. Nilesh S. Vikamsey
President

THE INSTITUTE OF CHARTERED ACCOUNTANTS OF INDIA

(Set up by an Act of Parliament)

23rd October, 2017

ICAI/DTC/2017-18/Rep-31

Shri Arun Jaitley,
Hon’ble Finance Minister,
Ministry of Finance,
Government of India,
North Block,
New Delhi -110 001.

Hon’ble Sir,

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.

Suggestion:

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.

Thanking you,

Yours faithfully,
(CA. Nilesh S.Vikamsey)

End: As above

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221 Comments

  1. joseph v varghese says:

    as the last months our office is fully engaged to educate and filing the assesses the benefits and procedures of GST , we could not find enough time for Tax Audit. Hence the extention of due date is most appreciate.

  2. azhar says:

    sir why other states not showing interest in this issue sir, why they are not co operating last in year 2015 from all corner of country represented and gone to high court now what happened

  3. Rajesh Sonkamble says:

    Thank you very much to ICAI for requesting the extension of Tax Audit Due Date. Hon’ble Finance Minister sir please.allow our request.

  4. nagaraj pawaar says:

    Businessman is busy in satisfying the requirement of GST returns and struggling for understanding on late fees, RCM etc & not able to submit the records for audit & attend the audit querries in time. Consider the genuine reasons and extend the tax audit due date to 30-11-2017

  5. azhar says:

    sir these comments whether they know or just we are writing and reading. if we get the results so that we can plan accordingly please put pressure sir as only 6 days sir this is very very needful issue sir

  6. C V Promod says:

    Sir my humble submission and prayers before Hon.FM andmand members of CBDT to extend till 30 Nov 2017 to file tax audit reports this will help small auditors and tax consultants like who entirely depend on small practice sir please consider my request

  7. MYM says:

    thank you very much to ICAI for requesting the extension of Tax Audit Due Date
    and FM and CBDT should take decision as soon as possible, Pls don’t wait last date for extension, we are under huge pressure of GST work and going to depression

  8. Prashant B Mer says:

    GST Return not complete First time for all and its process so legthy so i also with ICAI Institute for extend date of audit report and IT Return

  9. SIDDHESH T. YADAV says:

    Thanku so much ICAI for requesting the extension of Tax Audit Due Date. and Please dont wait CBDT for Last movement for extension we are already in Depression for GST Returns and Late fees

  10. Pramod Agrawal says:

    The work will never complete if there is no pressure. The pendency is because of clients who are habitual of coming on last day .Why we CA should take pain . The request for extension should be from Business community and not from professionals

  11. rambabu says:

    dear PM , FM and CBDT, we are requested to you, plz extension due date of tax audit for ay 2017-18, we are under more pressure, loss of health and personal life also.

    so we are appeal to all of tax professionals and practitioners don’t loss of health.

    we are also inform to you – we came to know 2nos. of accountants in one of tirupathi area and another of machilipatnam area are yesterday dead, due to under pressure of work from last 3 months onwards,

  12. Chandan Kumar says:

    FM and CBDT should take decision as soon as possible, Pls don’t wait last date for extension, we are under huge pressure of GST work and going to depression

  13. Kiritbhai says:

    We are thankful to the ICAI for this request for extension of time limit for conducting of tax audit and filing of Income Tax Returns which is inevitable this year.
    we are with you.

  14. nisarg says:

    We are thankful to the ICAI for this request for extension of time limit for conducting of tax audit and filing of Income Tax Returns which is inevitable this year.
    we are with you.

  15. KETAN says:

    We are thankful to the ICAI for this request for extension of time limit for conducting of tax audit and filing of Income Tax Returns which is inevitable this year.
    we are with you.

  16. Rajeev Ranjan Basak says:

    Today is 26th October, only 6 day remaining to last date for filling tax audit. till today no any extension reflect in income tax portal.. Pata nahi ICAI ki guhar F.M. sunega bhi ya nahi.

  17. CA Prasun Kumar Bhattacharyya says:

    The imposed October 2017 calendar has more committing dates for compliance – it may be seen. What is understood is that the Government wants to have the self assessment tax liquidated by 31/10/17 as it needs funds – the Govt. can put in the condition of charging interest in self assessment tax deposted after 31/10/17. That way none suffers – extension till 30/11/17. Interest chargeable on sa tax paid after 31/10/17.

  18. K.CH.A.V.S.N MURTHY( a2z Murthy) says:

    thanks to ICAI and advance thanks to the Hon’ble FM
    this extension relieves every body in the country connected to the subject

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