A Logical Demand: Extension of ITR & Tax Audit Report Dates for AY 2025-26

The issue of extending due dates for filing Income Tax Returns (ITRs) and Tax Audit Reports (TARs) is not a matter of convenience but of sheer practicality. In most Indian cities, the same set of professionals handle both return filing and audit work. When the ITR filing deadline is pushed forward by the Government itself, it automatically compresses the available time for audit assignments. This year, the situation is particularly acute, leaving professionals with an impossible timeline.

This year i.e. in the Assessment year 2025-26 the due date for filing of non-audited ITRs was 31^st. July 2025 which was extended to 15^th Sept, 2025 without any demand from the Taxpayers or professionals and the Tax audit report date is 30^th Sept, 2025. In our county in most of the cities same professionals are doing both the work so practically the audit work starts from 1^st. Sept but now due to delay from the Government side it will now start from 16^th Sept 2025 hence it will not be possible for the professionals to complete it on or before 30^th Sept. 2025.  Further due to portal glitches and problems the date of ITR is not possible to catch by all the Tax payers. Hence both the dates need some relaxation.

Let us see what it the problem and how a very useful  draft of  memorandum can be prepared so that various trade and professional association can use it to be presented to concerned authorities and ministry.

Key Issues

Compressed Compliance Window:

Non-audit ITR due date extended to 15 Sept 2025 (without any demand from professionals and Tax payers and Leaves only 15 days before audit work begins, instead of the traditional 2 months.

Technical Hurdles:

Utilities for ITRs and TAR released very late. The TAR facility still has to face the rush. E-filing portal continues to face glitches, downtimes, OTP failures.

Overlap of Responsibilities:

Same professionals handle both ITRs and audits. Parallel GST, MCA, PF/ESI compliances add to the burden.

Audit Complexity:

Tax Audit involves 40+ clauses of Form 3CD Plus some New requirement regarding MSME payments. Rushed timelines risk errors, omissions, and litigation.

Equity & Precedents:

In GST & MCA, extensions are routine where technical issues arise.

Similar fairness is expected under Income-tax as well.

The  Request

Non-Audit ITR filing – Extend to 30th September 2025

Tax Audit Report (TAR) filing – Extend to 30th November 2025

This restores the logical 2-month gap between ITR and audit compliance.

Assurance from the Tax professionals and Tax payers :-

Taxpayers & professionals are fully committed to compliance.

Extension will ensure: Better quality & accuracy , Reduced stress & errors Stronger voluntary compliance

Let us have a draft memorandum from a Tax Payer and Tax professionals Associations so that any association wants to represent can use it with suitable amendments. 

To
The Hon’ble Finance Minister of India
Government of India
North Block, New Delhi

Subject: Representation for Extension of Due Dates for Filing of Income Tax Returns and Tax Audit Reports for AY 2025-26

Respected Madam,

We, on behalf of the Tax Professionals & Tax Payers , respectfully submit this representation regarding the urgent need to extend the statutory due dates for filing Income Tax Returns (ITRs—non-audit cases) and furnishing of Tax Audit Reports (TAR) for the Assessment Year 2025-26.

Our request arises from genuine practical hardships faced by taxpayers and professionals alike, and is placed in the larger interest of ensuring fair, smooth, and quality compliance under the Income-tax Act, 1961.

1. Position of Due Dates and Compressed Calendar

-Traditionally, the due date for non-audit ITRs is 31st July. After this, professionals begin focusing on audit cases from 1st September onwards, allowing nearly two months exclusively for audits.

– In the current year, the non-audit ITR due date has been extended up to 15th September 2025, although there was no demand from taxpayers or professionals for such extension. This is purely based needed extension .

– This has created an overlap, where only 15 days remain between non-audit ITR filings and audit assignments, thereby disrupting the natural and logical compliance calendar.

2. Technical and Procedural Issues with the E-filing Portal

The Income Tax e-filing portal still suffers from technical glitches, downtimes, and failures—especially during peak periods. Uploading ITRs and TARs often requires repeated attempts.

Utilities for several ITR forms and TAR-related functionalities were released very late this year. Ideally, utilities should be available by the first week of April, but the delay has significantly shortened the compliance season.

Frequent system errors, OTP failures, and slow portal response times have made the compliance environment unnecessarily stressful.

3. Overlap of Responsibilities and Human Limitations

The same set of professionals (Mostly Chartered Accountants) are responsible for both ITR filings and audit reports and audited returns . Audit in all the cases were done by chartered accountants who are in most of the cities also providing services of filing of non-audited returns. Tax professionals are also responsible for filing for Audited and Non audited ITRs.

By shifting the non-audit ITR deadline to mid-September, the audit season is squeezed into a highly compressed and unrealistic window, leaving little breathing space for detailed examination and reporting.

Professionals also shoulder multiple other responsibilities simultaneously—GST returns and audits, MCA compliances, PF/ESI filings, bank audits, and corporate assignments—making the overlap practically unmanageable.

4. Complexity of Tax Audits and Quality Concerns

A Tax Audit under Section 44AB is an in-depth compliance exercise, not a mere formality. It requires verification of books of account, cross-checking with GST returns, TDS statements, PF/ESI compliance, reporting under 40+ exhaustive clauses of Form 3CD, ensuring consistency with Income-tax and other laws. A hurried audit is not possible since it  leads to errors, incomplete disclosures, and subsequent litigation. Instead of strengthening compliance, such compression defeats the very intent of audit provisions. It requires sufficient and reasonable time.

5. Principles of Natural Justice and Equity

The unrequested extension of non-audit ITR filing has effectively reduced the audit period, punishing taxpayers and professionals for no fault of theirs. Natural justice demands that adequate time be provided for meaningful compliance. Compliance should be fair, practical, and error-free, not rushed. Quality compliance benefits not just taxpayers but also the Department by reducing future disputes, notices, and litigation.

6. Parity with Other Laws and Precedents

In GST and MCA frameworks, extensions are frequently granted when technology or compliance pressure warrants relief. Income-tax compliance, being far more voluminous and consequential, logically deserves equal consideration and fairness.

7. Wider Stakeholder Impact

Taxpayers, especially small businesses and MSMEs, are already struggling with working capital pressures, changing GST rules, and economic slowdowns. They rely heavily on professionals for accurate tax compliance. Tax payers are not in a position to bear the burden of Penalty in delay of Tax audits.

Tax professionals and their staff are overstretched. Continuous late-night working, weekends without rest, and overlapping compliance schedules are leading to burnout, health issues, and declining quality of output.

Extension of due dates will ensure smoother workload distribution, reduced stress, and better compliance for all stakeholders.

8. Our Humble Request

In view of the above, we request your kind intervention to extend the following due dates: Non-Audit ITR Filing: Extend to 30th September 2025 (instead of 15th September 2025). Tax Audit Report (TAR) Filing: Extend to 30th November 2025.

This will restore the logical two-month gap between non-audit ITR filings and audit compliance, which has been the natural system followed for years.

9. Assurance of Commitment

We assure you that taxpayers and professionals are committed to timely and responsible compliance. Our request is not intended to delay obligations but to ensure that compliance is:

Carried out with quality and accuracy, completed without undue pressure, aligned with realistic timelines and technical limitations, and consistent with the larger objectives of tax administration.

We trust that the Ministry will consider this logical and fair request favourably. Extending the due dates will not only relieve undue pressure on taxpayers and professionals but will also promote higher quality compliance and reduce litigation—objectives that serve both the Department and the nation’s tax system.”

We sincerely hope that the Ministry will appreciate the practical realities on the ground and provide the requested relief, which will reduce stress, improve quality, and strengthen voluntary compliance in the long run.

With highest regards,

Yours faithfully,

For Tax Professionals & Tax Payers Association
[Name & Designation]
[Contact Details]