With the COVID-19 pandemic playing havoc and resulting in many practical challenges, the Indian Government has come out with various relief measures and also extended different statutory deadlines.

Recently, the Finance Ministry via Press Release and as per Notification No. 88/2020 issued by CBDT dated 29 October 2020 announced further extension of deadlines for filing of Income Tax Return and furnishing of Tax Audit Reports and Transfer Pricing (TP) Reports.

Sr. No. Particulars Period Actual Due Date Last Extended Due date New Due Date
1 Income Tax Return u/s 139 (Revised or Belated Return) AY 2019- 20 31st March 2020 30th September, 2020
(earlier extension was up to 31st July,2020)
30th November, 2020
2 Income Tax Return u/s 139 (In cases of assessee to whom TP Audit, Company Audit and Tax Audit is applicable) AY 2020-21 31st October 2020/ 30th November 2020 30th November 2020 31st January, 2021
3 Income Tax Return u/s 139 (Other than Sr. no. 2 above) AY 2020-21 31st July, 2020 30th November, 2020 31st December, 2020
4 Self – Assessment (SA) Tax Liability. No interest chargeable under Section 234A, if the SA Tax liability is up-to INR 1 Lakh AY 2020-21 On or Before 31st July 2020/ 31st October 2020 30th November 2020 31st January, 2021
(In case of
assessees not
requiring any Audit, it is 31st December,
2020)
5 Filing of Tax Audit Report under section 44AB and TP Report under section 92E of the IT Act AY 2020-21 30th September, 2020 31st October, 2020 31st December, 2020
Filing of Master file in Form 3CEAA-Part A and /or Part B AY 2020-21 30th November 2020 30th November 2020 No clarification
presumed to be 31st January, 2021*
Intimation for Master File – Form 3CEAB AY 2020-21 31st October 2020 31st October 2020 31st December, 2020*
Safe Harbour Rule – Form 3CEFA AY 2020-21 30th November 2020 30th November, 2020 31st January, 2021*
Filing of Intimation in Form 3CEAC Country by Country Reporting AY 2020-21 31st January 2021 31st January, 2021 No Change
31st January, 2021
Filing of Form 3CEAD Country by Country Reporting AY 2020-21 31st March 2021 31st March, 2021 No Change 31st March, 2021
6 Deduction available under Chapter VI A, in heading B (e g., 80C, 80D, 80G etc.) AY 2020-21 31st March 2020 Investments/payments can be made
up-to 31st July 2020 (earlier extension was up to 30th June, 2020)
No Change
31st July, 2020
7 Capital Gain Exemption u/s 54 to 54GB AY 2020-21 Due dates as per Income Tax Act Investments/payments/ construction
can be made up-to 30th September 2020 (earlier extension was up to 30th June, 2020)
No Change
30th September, 2020
8 Furnishing of TDS/ TCS Statement (Returns) Q4 of AY

2020-21

31st May 2020 31st July 2020 (earlier extension was up to 30th June, 2020) No Change
31st July, 2020
9 Issuance of TDS/ TCS certificate AY 2020-21 15th June 2020 15th August 2020 (earlier extension was up to 15th July, 2020) No Change
15th August, 2020
10 Linking of Aadhar with PAN 30th June 2020 31st March 2021 No Change
31st March, 2021
11 Payment under Vivad se Vishwas Act, 2020 31st March 2020 31st December 2020
(earlier extension was up to 30th June, 2020) If payment was made on or after 31st December 2020, additional 10% of the disputed tax amount shall be payable
As per Notification
dated 27 October
2020 31st March 2021**
Declaration to be filed before the designated authority under Vivad se Vishwas Act, 2020 31st March 2020 31st December 2020 (earlier extension was up to 30th June, 2020) 31st December 2020**
12 Commencement of Operation for Special Economic Zone units under section 10AA of the IT Act 31st March 2020 30th September 2020 (earlier extension was up to 30th June, 2020) No Change
30th September, 2020
13 Matters other than specifically provided:

a. Completion of any proceeding or passing of any order or issuance of any notice, intimation, notification, sanction or approval or such other action, by whatever name called, by any authority, commission or tribunal, by whatever name called, under the provisions of the specified Act; or

  • Filing of any appeal, reply or application or furnishing of any report, document, return, statement or such other record, by whatever name called, under the provisions of the specified Act
Deadline falling between
20th March 2020 and 31st December 2020
31st March, 2021 No Change
31st March, 2021
14 In case where any due date for making payments towards any tax or levy under the specified Act falls between 20.3.2020 and 29.6.2020 and where such tax or levy has been paid on or before 30.6.2020, Interest would be levied at a reduced rate of 0.75% p.m. Further no penalties or prosecution shall be initiated in respect of such amount for the period of delay. No clarification on extension of date for the same is issued.

Our Comments:

*Though there is no specific mention in the aforesaid CBDT Notification, however, as the due date for filing Return of Income has been extended, the due date for filing, Intimation in Form No. 3CEAB, Master File in Form No. 3CEAA, and also filing Form No. 3CEFA for opting in favour of the Safe Harbour Rules, should also be read as being duly extended. Further, in order to provide clarity, it would be better if CBDT would also clarify the above aspects.

** The Ministry of Finance has issued a Notification No 85/2020 dated 27 October, 2020, under the Vivad se Vishwas Act, 2020, that in order to mitigate undue hardship and remove difficulty that may be caused by the requirement of payment within 15 days from date the date of receipt of certificate from designated authority, allows the declarant to make the payment without any additional amount till on or before 31st March, 2021. Further, the declaration can be filed by 31 December, 2020.

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