MPTCA Seeks Tax Audit and ITR Due Date Extension for AY 2026-27

Summary: Madhya Pradesh Tax Consultants Association (MPTCA), in its representation dated 21 September 2026 to the Union Finance Minister, has sought immediate extension of tax audit and related compliance due dates for AY 2026-27, citing the compressed compliance calendar and practical difficulties faced by taxpayers and tax professionals. The Association requests extension of the due date for Tax Audit Reports in Forms 3CA/3CB read with Form 3CD and Forms 10B/10BB from 30 September 2026 to 30 November 2026, and extension of the audited Income-tax Return due date from 31 October 2026 to 31 December 2026, together with corresponding consequential extensions. The representation states that extension of the non-audit business/profession return deadline to 31 August 2026 effectively leaves September for tax-audit assignments. It refers to the substantive nature of tax audits, progressive availability and updating of ITR utilities, late availability and reconciliation of TDS/TCS, SFT, AIS, TIS and Form 26AS information, simultaneous statutory and professional assignments, revised financial-reporting requirements and transition to the Income-tax Act, 2025. For future years, MPTCA proposes advancing TDS/TCS and SFT reporting preferably to 30 April, rationalising return deadlines, aligning the Tax Audit Report and audited ITR due dates at 31 October, providing a meaningful audit season and establishing a predictable permanent solution.

Madhya Pradesh Tax Consultants Association (MPTCA)

Ref. No.: MPTCA/DT/2026-27/17 | Dated: 21^st Sept., 2026

To,
The Hon’ble Union Minister of Finance
Smt. Nirmala Sitharaman Ji
Ministry of Finance
Government of India
New Delhi – 110001

Subject: Representation seeking immediate extension of the due dates for Tax Audit Reports, Forms 10B/10BB and consequential Income-tax Returns for AY 2026-27, and rationalisation of the compliance calendar for future years

Respected Madam,

We, the Madhya Pradesh Tax Consultants Association (MPTCA), most respectfully submit this representation for your kind and urgent consideration regarding the extremely compressed compliance calendar for Assessment Year 2026-27 and the practical difficulties being faced by taxpayers, Chartered Accountants, tax consultants, accountants and other professionals across the country.

At the outset, we respectfully acknowledge the continuous efforts of the Government and the Central Board of Direct Taxes towards simplification, digitisation and rationalisation of income-tax compliance. We particularly appreciate the Government’s decision to provide in the law the due date for filing returns of income of business/profession assessees who are not liable to tax audit from 31 July 2026 to 31 August 2026.

However, the consequential effect of this change, coupled with the present statutory due date of 30 September 2026 for furnishing Tax Audit Reports, has resulted in a serious and unprecedented compression of the effective period available to the tax profession for completing tax audits and allied audit assignments.

The Income-tax law presently specifies 30 September 2026 as the due date for furnishing the tax audit report for FY 2025-26 relevant to AY 2026-27, with the corresponding return of income in ordinary audit cases being due on 31 October 2026.

We therefore respectfully request that, as an immediate one-time measure for AY 2026-27, the following extensions may kindly be granted:

OUR IMMEDIATE REQUEST FOR AY 2026-27

Compliance	Present Due Date	Requested Due Date
Tax Audit Report in Forms 3CA/3CB read with Form 3CD	30 September 2026	30 November 2026
Forms 10B / 10BB and other consequential audit reports	30 September 2026	30 November 2026
Income-tax Return of audited business/profession cases	31 October 2026	31 December 2026
Consequential reports/returns having an interdependent audit requirement	As presently prescribed	Corresponding consequential extension

We respectfully submit the following detailed grounds in support of our request.

1. Effective audit period has been compressed to merely one month

For AY 2026-27, the due date for business/profession assessees not liable to tax audit was as per law allowed upto 31 August 2026 in place of 31^st July in earlier years.

Consequently, the same Chartered Accountants, tax practitioners, accountants and office staff who are engaged in preparing and filing a very large number of non-audit business and professional returns non-business returns throughout July and August are left with effectively only the month of September for completing the entire volume of tax-audit assignments.

Tax audit is not merely an online uploading exercise. It involves detailed examination, verification, reconciliation, professional judgement and reporting under the Income-tax Act and other applicable laws.

Thus, the practical consequence of the present calendar is that the tax profession has to complete a very large volume of non-audit returns by 31 August and thereafter undertake the entire audit season within approximately 30 days.

This compression is particularly acute for small and medium-sized practices which serve a large number of MSMEs, firms, professionals, trusts and other entities.

2. Tax audit is a substantive professional attestation exercise

A Tax Audit Report under section 44AB is a professional report involving responsibility of the Chartered Accountant for the information reported therein.

The auditor is required to examine and reconcile, wherever applicable:

• books of account and underlying records;
• financial statements;
• sales and purchase records;
• stock and inventory records;
• GST returns and GST turnover;
• TDS/TCS records;
• Form 26AS;
• AIS and TIS;
• bank statements;
• loans, advances and deposits;
• debtors and creditors;
• related-party transactions;
• statutory dues and payments;
• depreciation and fixed assets;
• provisions and contingent liabilities;
• payments covered under various disallowance provisions;
• cash transactions;
• specified domestic and international transactions;
• deductions and exemptions;
• accounting policies;
• ICDS requirements;
• Accounting Standards / Ind AS, wherever applicable;
• applicable ICAI guidance and professional standards; and
• numerous disclosures and particulars prescribed in Form 3CD.

The Income-tax Department itself describes Forms 3CA/3CB-3CD as audit reports and statements of particulars required under section 44AB.

Accordingly, adequate time is indispensable for a correct and reliable audit.

An extension does not dilute the statutory obligation; rather, it enables the taxpayer and auditor to discharge the existing obligation properly.

3. Progressive availability and updating of ITR utilities has reduced the effective time available

The current year has also witnessed the progressive availability and updating of various ITR forms/utilities required for business and audit cases.

Recent professional representations have specifically brought to notice that ITR-3, ITR-5, ITR-6 and other relevant utilities became available progressively during June, July and August 2026 and, in some cases, continued to be updated thereafter.

This is important because tax audit and the consequential income-tax return cannot realistically be treated as two completely independent exercises.

The particulars reported in Form 3CD and the audited financial statements have a direct bearing upon the preparation of the corresponding ITR.

Therefore, even where books and accounts are otherwise substantially complete, the finalisation of the audit and return is necessarily affected by the availability, functionality and subsequent updating of the relevant utilities.

4. TDS/TCS information becomes available very late in the return cycle

The fourth-quarter TDS statement is required to be furnished by 31 May following the financial year.

Similarly, the annual Statement of Financial Transactions (SFT) in Form 61A is generally required to be furnished by 31 May following the relevant financial year.

Consequently, important information relating to:

• TDS;
• TCS;
• SFT;
• interest;
• dividend;
• securities transactions;
• other reportable financial transactions; and
• related information reflected in AIS/TIS/26AS

is received and reconciled only after the financial year has ended.

The Income-tax Department itself explains that AIS contains TDS/TCS, SFT, tax payments and various other information, whileForm 26AS principally displays TDS/TCS information from AY 2023-24 onwards.

Therefore, April and May cannot practically be regarded as fully productive months for finalisation of tax returns and audits because substantial third-party information remains under reporting/reconciliation.

5. April to June is substantially consumed in collection and reconciliation of information

During April, May and June, taxpayers and professionals are engaged in:

• finalisation of books;
• preparation of financial statements;
• GST annual reconciliation;
• TDS/TCS reconciliation;
• obtaining Form 16/16A and other certificates;
• reconciliation of Form 26AS;
• checking AIS/TIS;
• verification of SFT information;
• bank reconciliation;
• debtor/creditor confirmations;
• stock records;
• fixed-asset schedules;
• statutory payment verification;
• collection of supporting documents.

The availability of AIS itself is dependent upon information reported by multiple information sources.

Hence, the period from April to June cannot be treated as three full months available for tax-audit completion.

6. July and August are consumed by non-audit return compliance

Once the relevant information becomes substantially available, the tax professional enters the peak season for preparation and filing of non-audit returns.

The Government has, for AY 2026-27, fixed 31 August 2026 as the due date for ITR-4 and other applicable non-audit business/profession cases.

The same professional establishment, staff and accounting infrastructure is then expected to immediately shift to hundreds or thousands of audit assignments with a deadline of 30 September.

This creates an artificial bottleneck and increases the risk of errors in a compliance area where accuracy and professional judgement are of paramount importance.

7. September is not an uninterrupted working month

The month of September also contains various festivals and local holidays in different parts of the country, including Madhya Pradesh.

Tax audit requires interaction between the auditor, proprietor/partners/directors, accountants, employees, bankers, GST consultants, legal advisers and other persons responsible for providing information.

The availability of clients and supporting personnel is therefore not uniform throughout September.

8. Simultaneous statutory and professional audits

Chartered Accountants are not engaged only in Income-tax Tax Audits during September.

The same professionals are simultaneously required to attend to:

• statutory audits;
• tax audits;
• GST-related reconciliations;
• trust audits;
• Forms 10B/10BB;
• company law compliances;
• MCA filings;
• internal audits;
• bank audits and other assignments, wherever applicable;
• TDS/TCS matters;
• certification work; and
• other professional assignments.

Recent professional representations have similarly pointed out the overlapping GST, TDS/TCS, MCA and other statutory compliance burden.

Therefore, retaining only one month for tax audit work is neither practically convenient nor conducive to quality compliance.

9. Revised financial reporting requirements have increased the work involved

The ICAI has prescribed the phased applicability of its Guidance Note on Financial Statements of Non-Corporate Entities and Guidance Note on Financial Statements of Limited Liability Partnerships.

For annual reporting periods beginning on or after 1 April 2025, the first phase applies to specified entities having turnover exceeding ₹5 crore, while from periods beginning on or after 1 April 2026 the requirements apply to all entities covered by the announcement.

This necessarily involves additional attention to presentation, classification, disclosures and preparation/review of financial statementsand a very time consuming exercise in case of fresh drafting of the new format because almost all non-corporate entities were earlier adopting horizontal format of financial statements and now they have to wholly reframe the current year as well as previous year data in current year financial statements of the F.Y. 2025-26 (AY. 26-27).

The increased financial-reporting requirements should also be considered while determining the realistic time available for tax audit.

10. Transition to the Income-tax Act, 2025 has added to the compliance environment

AY 2026-27 is also a year of transition, because the Income-tax Act, 2025 comes into the compliance framework while AY 2026-27 continues to be governed by the Income-tax Act, 1961 for the relevant year.

The Income-tax Department has specifically clarified that the tax audit report for FY 2025-26 / AY 2026-27 continues to be furnished in Forms 3CA/3CB and 3CD under the 1961 Act.

During the current financial year 2026-27 (Tax year 26-27) most of the tax professional were very much busy since last many months and are to remain busy in coming months to read and understand New Income Tax Act 2025 and Rule 2026 and to educate their clients/taxpayers about the new income tax act 2025 and smooth transitioning, which had left with them a very less available time to carry out tax audit and other audit assignments for the assessment year 2026-27 (F.Y. 2025-26). During this financial year 2026-27 the tax professional and tax payers are having to handle two income tax act simultaneously i.e Income Tax Act 1961 and Income Tax Act 2025 because returns and audit etc. processes and procedures of repealed 1961 act are still continuing e.g. returns filing, ITR filing, 148 notices, assessments, appeals etc. and at the same time TDS TCS statements and various compliances under new income tax act 2025 and rules 2026 have already commenced and are undergoing for which proper training to staff, tax professionals, clients etc. is needed and is undergoing which has left all the tax professional with least available time for tax audits for AY. 2026-27.

This transition necessarily requires professionals to simultaneously keep track of two legislative frameworks and their respective forms, rules and procedures.

11. Difficulties relating to AIS, TIS and Form 26AS

AIS has become an important source of information for preparing and reconciling income-tax returns.

It contains, inter alia:

• TDS/TCS information;
• SFT information;
• tax payments;
• demand/refund information;
• GST information;
• information received from foreign governments; and
• other financial information.

The Income-tax Department itself states that AIS contains information beyond the TDS/TCS information displayed in Form 26AS.

However, taxpayers frequently need to reconcile such information with books of account and underlying documents.

Such reconciliation cannot be responsibly completed merely by downloading the AIS and mechanically importing figures into the return.

12. Tax audit and income-tax return are interdependent

The present system provides approximately one month between the tax audit due date and the return due date.

In theory, this one-month interval is intended to facilitate preparation of the return after completion of the audit.

In practice, however, a substantial portion of the ITR data has to be prepared simultaneously with the audit.

Moreover, the practical expectation that a pre-filled return will completely eliminate manual preparation does not reflect the actual nature of business and professional returns.

Audited business returns often require substantial manual review, reconciliation and insertion of information arising from the financial statements and Form 3CD.

Therefore, the one-month gap between the two due dates does not provide the benefit that may have been contemplated. Therefore this one month gap is problematic and time wasting rather than helping or relaxing therefore in furture the tax audit report due date and tax audit returns due date should be the same without any gap of one month.

13. The proposed extension will not cause any loss of revenue to the Government

The requested extension is essentially a request for time for compliance, and not for postponement or waiver of tax liability.

The taxpayer would continue to be liable for:

• advance tax;
• self-assessment tax;
• applicable interest;
• statutory taxes and other liabilities.

The extension would merely enable proper preparation and filing of audit reports and returns.

On the contrary, adequate time would improve the quality and accuracy of reporting and reduce subsequent rectification, revised return, defective return and litigation-related issues.

14. Various and frequent changes in law and rules- consume time in audit reports preparation and presentation:

The substantial additional work arising from changes in income tax law and rules and various circulars and clarifications and notifications and relevants court judgments all have to be much taken care of while preparing audit reports in Form 3CD and trust audit reports etc., difficulties relating to various clauses of the audit report, issues requiring clarification, and the additional compliance burden in respect of charitable/religious trusts and institutions.

The fundamental concern has not changed during the current season of tax audit.

Tax audit etc. has to be completed with adequate time for proper examination and professional judgement rather than under an artificial last-minute deadline.

OUR HUMBLE REQUEST

In view of the foregoing genuine and practical difficulties, the Madhya Pradesh Tax Consultants Association most respectfully requests the Hon’ble Union Finance Minister to kindly consider the following immediate relief for AY 2026-27:

A. Tax Audit and allied audit reports

The due date for furnishing:

Forms 3CA/3CB along with Form 3CD, Forms 10B/10BB and other consequential audit reports

may kindly be extended from:

30 September 2026 to 30 November 2026.

B. Consequential audited Income-tax Returns

The due date for filing Income-tax Returns of assessees whose accounts are subject to tax audit may kindly be extended correspondingly from:

31 October 2026 to 31 December 2026.

C. Consequential extension

All consequential due dates, wherever linked to the above audit reports and returns, including applicable reports under sections 92E and other allied provisions, may kindly be extended correspondingly so that the benefit of the extension is complete and effective.

LONG-TERM RATIONALISATION OF THE INCOME-TAX COMPLIANCE CALENDAR

While the immediate extension for AY 2026-27 is urgently required, we respectfully submit that the recurring necessity for professional bodies to approach the Government every year for extension of due dates can be permanently eliminated by rationalising the compliance calendar.

We therefore make the following suggestions for consideration for AY 2027-28 and subsequent years.

1. Advance the TDS/TCS reporting cycle

The Government may kindly examine the possibility of substantially preponing the due date for the fourth-quarter TDS and TCS statements.

The objective should be that the relevant TDS/TCS information and certificates are available to taxpayers and professionals sufficiently early in the succeeding financial year, preferably on or before 30^th April.

This would substantially facilitate:

• reconciliation of TDS/TCS;
• preparation of books;
• preparation of financial statements;
• preparation of tax audit;
• preparation of ITRs; and
• reduction of AIS/26AS mismatches.

At present, the fourth-quarter TDS statement is due on 31 May.

2. Prepone the SFT reporting date

The annual SFT in Form 61A is presently required generally by 31 May following the financial year.

The Government may kindly examine whether the SFT reporting cycle can be advanced so that the relevant SFT information is available to taxpayers substantially earlier, preferably by 30^th April.

This would materially improve the accuracy of AIS and facilitate timely reconciliation.

3. Rationalise the return-filing calendar permanently

We respectfully suggest the following simplified three-tier structure for future years:

Category	Suggested Due Date
Non-business / non-audit assessees	30 June
Business/profession assessees not liable to audit	31 July
Tax-audit / audited business and professional cases	31 October

This would create a predictable and rational compliance calendar.

4. Tax Audit Report and audited ITR should preferably have the same due date

We respectfully suggest that, in the long term, the due date for the Tax Audit Report and the consequential audited Income-tax Return may be aligned.

Accordingly:

Tax Audit Report + Audited ITR = 31 October

would be a more logical and practical arrangement.

There would then be no artificial one-month gap between the tax-audit report and the ITR.

The present system contemplates the tax-audit report one month before the return due date.

However, in actual professional practice, audit and return preparation are interdependent and are often undertaken simultaneously.

5. Provide a meaningful audit season

If the non-business/non-audit and business non-audit return deadlines are rationalised as suggested above, Chartered Accountants would have the month of August and September substantially available for tax-audit work, with October available for completion/finalisation and filing of the audited ITR.

This would eliminate the present situation where professionals move from one deadline immediately into another without any meaningful interval.

6. Avoid annual dependence upon extension notifications

The tax professionals should not be required every year to make representations in September seeking extension of tax-audit dates.

A rational and predictable compliance calendar would benefit:

• taxpayers;
• Chartered Accountants;
• tax consultants;
• the Income-tax Department;
• GST authorities;
• banks and financial institutions; and
• the overall tax administration.

It would also enable the Department to receive better-quality and more accurately reconciled information.

A HUMBLE APPEAL FOR A PERMANENT SOLUTION

Madam, the issue before us is not merely the convenience of tax professionals.

It concerns the quality, accuracy and reliability of statutory tax reporting.

A tax audit report is a professional attestation document. It should be prepared only after adequate examination of books, records, financial statements, statutory compliances, third-party information and relevant legal provisions.

An extremely compressed deadline inevitably creates avoidable pressure on taxpayers, accountants and auditors and may increase the possibility of inadvertent errors.

The objective of the Government and the professional community is ultimately the same:

correct reporting, timely compliance, proper payment of tax and reduction of litigation.

A well-designed compliance calendar would advance all these objectives.

We therefore earnestly request the Hon’ble Finance Minister to kindly:

1. extend the Tax Audit Report and allied audit-report due date for AY 2026-27 from 30 September 2026 to 30 November 2026;

2. extend the due date of audited Income-tax Returns for AY 2026-27 from 31 October 2026 to 31 December 2026;

3. grant corresponding extension for Forms 10B/10BB and other consequential audit reports;

4. grant corresponding consequential extension wherever any other statutory report or return is linked with the above dates;

5. consider preponing the TDS/TCS reporting dates for the coming year so that complete information is available substantially earlier in the succeeding financial year;

6. consider preponing the SFT reporting date so that SFT information becomes available to taxpayers and professionals preferably by 30^th April;

7. rationalise the permanent return-filing calendar so that:

• • non-business/non-audit returns are due by 30 June;
  • business/profession non-audit returns are due by 31 July; and
  • audited business/profession returns are due by 31 October;

8. permanently align the Tax Audit Report and audited Income-tax Return due dates, preferably with 31 October as the common due date; and

9. establish a predictable annual compliance calendar so that taxpayers and professionals are not required to seek extensions every year.

We sincerely hope that the Hon’ble Finance Minister will kindly consider this representation sympathetically and issue the necessary notification/order at the earliest, keeping in view the genuine hardship being faced by taxpayers and the professional community throughout the country.

We remain confident that this measure will improve the quality of compliance, reduce errors, facilitate better tax administration and ultimately serve the larger public interest.

With profound regards,

Yours faithfully,

For Madhya Pradesh Tax Consultants Association (MPTCA)

PRESIDENT SR. ADV. SUMIT NEMA 97131 63667	VICE PRESIDENT CA. Rajesh Mehta 98270 36956
Indore Zone Chairman CA. S. N. Goyal 98260 21279	Indore Zone Secretar CA. S. S. Solanki 98260 52321