Tax Bar Association, Bhilwara  has requested for extension of Due Date of filing of Tax Audit and Income Tax Return for Assessment Year 2020 due to COVID 19 Pandemic. Request is been made to Hon’ble Finance Minister, Smt. Nirmala Sitaraman. It is requested to further extend the due date of filing tax audit report to 28 February 2021 and Income tax return filing to 31 March. Full text of the Representation is as follows:-

Date: 15th Dec. 2020

Smt. Nirmala Sitaraman
Hon’ble Finance Minister,
Ministry of Finance,
Government of India,
North Block,
New Delhi 110 001

Subject: Request for extension of Due Date of filing of Tax Audit and Income Tax Return for Assessment Year 2020 due to COVID 19 Pandemic.

The Tax Bar Association Bhilwara is organization of tax practitioners of Bhilwara having Advocates, Chartered Accountants and Tax practitioners having more than 200 members.

At the outset, we would like to convey our sincere thanks and gratitude to the Government for the way the pandemic has been efficiently tackled. Also to the Finance Ministry to provide extension of due dates of filing Income tax audit report and income tax return (non-tax audit cases) filing upto 31 December 2020 and Income tax return filing (tax audit cases) 31 January 2021 considering the COVID 19 conditions.

As you are aware, there is sudden increase in the COVID 19 cases across India. Our Bhilwara is worst affected from COVID 19 pandemic. Bhilwara has been receiving hundreds of cases on daily basis with more than 10000 cases reported till date.

Bhilwara cases reportedFurther, we wish to highlight as under:

1. Curfew at Bhilwara

Considering the increased number of cases in Bhilwara, the Administration imposed curfew till 16 November 2020. As on today, the Administration has imposed curfew in containment zones. Further, since 22 November 2020, the Authorities have imposed night curfew from 8 pm to 6 am. During the night curfew, all markets, work places and commercial complexes shall be closed by 7 pm. Considering the curfew, the tax professionals are left with limited working hours to complete the work.

2. Various businessmen, accountants and tax professionals have been tested positive and were under quarantine. This has resulted into delay in completing audits and filing of Income-tax returns.

In many cases, the work is hampered due to cases of COVID 19 being in stages. For eg. Once the accountant is tested positive, the work was stopped for 20 days. Once he joined back, the business man/ professional staff is tested positive. In this manner, the work is delayed by more then 1-2 months.

3. The reporting requirement of tax Audit and statutory audit requires various information to be checked and feeded in forms. In many cases, reporting is pending due to non-availability of details. Considering the limited staff availability, lesser visits to the client place, calling for information via scanned or couriers, limited working hours, it is taking a lot more time to complete an audit as compared to earlier years.

4. Long term effect: Considering the heavy medication during the COVID -19 treatment, even after recovering from COVID, businessmen and professional staff are taking time resume offices. This is also impacting the efficiency of our professional staff. Even doctors are advising to take precautions even after recovering from COVID-19.

5. Festive season: As you are aware, due to COVID19 the business of many MSME were impacted severely. The business man got a chance during the festive season to recover the losses and streamline the business. However, he is also required to focus on complying with statutory due dates. Many time he has to visit tax professionals offices during the peak business hours to get his compliance done in due time.

6. Updation in utilities and instructions:

The utilities are being updated with various bugs fixes:

Form Excel Utility Java Utility
ITR 1 01-12-2020 01-12-2020
ITR 2 10-12-2020 01-12-2020
ITR 3 01-12-2020 01-12-2020
ITR 4 01-12-2020 01-12-2020
ITR 5 03-12-2020 10-12-2020
ITR 6 03-12-2020 03-12-2020
ITR 7 08-12-2020 08-12-2020

Further, revised instructions to file various ITRs were issued on 22 November 2020 to provide clarity in filing of ITR.

7. Various due dates being overlapped: Along with the aforesaid Income-tax due dates, there are other compliance with due date of 31 December 2020.

a. GST annual return for FY 201819 (GSTR 9/9A) – 31 December 2020

b. GST Audit/ Reconciliation statement (GSTR 9C) for FY 201819 – 31 December 2020

c. The due date for holding AGM for corporate entities can not be extended beyond 31 December 2020

d. The due date for filing declaration under Direct Tax Vivad se Vishwas Act 2020 is 31 December 2020

These bottlenecks are making it difficult for the assessee, the accounts and the tax professionals to comply even with the extended due dates.

In view of the above genuine difficulties being faced by tax payers and tax practitioners due to outbreak of COVID 19 pandemic, we would request you to further extend the due date of filing tax audit report to 28 February 2021 and Income tax return filing to 31 March at the earliest. The entire fraternity of tax payers and professionals will highly appreciate if this is done soon enough (i.e. well in advance).

We hope your honour shall take positive action to resolve the problems faced Secretary: by the members. We look forward to your kind support and cooperation.

Thank you

For: Tax Bar Association, Bhilwara
(CA Atul Somani)
(CA Amit Kumar Seth)
(CA Ankit Lakhotiya)


1. Hon’ble Chairman CBDT, New Delhi

2. The CCIT, Udaipur

3. The JCIT, Range-2, Ajmer

Download Full Text  of Representation in PDF Format

Also Read:-

S. No. Date Association Particulars with link
1 9 Dec 2020 Western Maharashtra Tax Practitioners Extend due dates of Tax Audit & ITR for AY 2020–21
2 12 Dec 2020 Gujarat Sales Tax Bar Extend GSTR-9/9A/9C due date for FY 2019-20 to 30/06/2021
3 12 Dec 2020 Chamber of Tax Consultants Extend due dates for Tax/Transfer Pricing Audit & ITR for AY 2020-21
4 12 Dec 2020 Tax Practitioner’s Association, Indore Extend due dates for filing Tax/TP Audit Report & ITR for AY 2020-21
5 14 Dec 2020 AGFTC, ITBC and CAA Extend due dates of Tax Audit Reports/ITR for A.Y. 2020-21
6 15 Dec 2020 BCAS, CAA (Ahmedabad), CAA (Surat), KSCAA & LCAS Request to Extend Due dates under GST & Income Tax
7 15 Dec 2020 Tax Bar Association, Bhilwara Request to extend Due Date of filing of Tax Audit & ITR
8 15 Dec 2020 Direct Taxes Professionals’ Association, Kolkata Extend due date of ITR & Tax Audit for AY 2020-21
9 16 Dec 2020 Lucknow CA Tax Practioners’ Association Extend Due date for filing Tax Audit Report & ITR
10 16 Dec 2020 Jamshedpur Chartered Accountants Extend Due Date of filing Tax Audit & ITR to 31.03.2021
11 13 Dec 2020 Direct Taxes Committee of ICAI ICAI requests for extension of various Income-tax due dates
12 10 Dec 2020 Udaipur Tax Bar Association Further extend due dates of ITR & Tax Audit Reports for FY 2019-20
13 15 Dec 2020 CA Social Affiliation (CASA) Extend Tax/TP Audit Report & ITR filing due date for AY 2020-21
14 19 Dec 2020 Chartered Accountants Association, Jalandhar Extend Due Dates for Tax Audit and Income Tax Return Filing
15 19 Dec 2020 All India Federation of Tax Practitioners (CZ) Request for extension of due dates of Tax Audit Reports/ITR
16 19 Dec 2020 Vyyapaar Mandal Association, Nagore & AIMTPA Extended Income Tax & GST Audit/Return/Compliance dates
17 17 Dec 2020 Emerging Businesses Chamber Of Commerce Extend due dates for Income Tax Audit & Returns for AY 2020-21
18 Dec 2020 The Uttar Pradesh Tax Bar Association Representation for Extension of time for Tax Audit & Return
19 19 Dec 2020 Tax Bar Association, Guwahati Extend Tax Audit/ITR due dates for AY 2020-21
20 21 Dec 2020 Tax Bar Association, Guwahati Extend due dates of GSTR-9/ GSTR-9C for FY 2018-19 & 2019-20
21 17 Dec 2020 Karnataka State Chartered Accountants Association Waive Late Fees for Delayed Filing of GST Returns
22 15 Dec 2020 Direct Taxes Professionals’ Association Extend Vivad Se Vishwas Scheme due date to 15.03.2021
23 15 Dec 2020 Direct Taxes Professionals’ Association Extend due date of AGM to 31st March 2021
24 15 Dec 2020 Association of Tax payers & Professional, Agra Extend due of GSTR-9, GSTR-9A & GSTR-9C
25 08 Dec 2020 Tax Bar Association (Regd), Allahabad Extend due date of ITR/Tax Audit/GSTR-9/GSTR-9C
26 08 Dec 2020 Tax Consultant & Practitioners Association of Kerala Extend due of ITR, GSTR 9, 9A & 9C for FY 2018-19 & 2019-20
27 21 Dec 2020 Tax Bar Association, Guwahati Extend CFSS 2020 & LLP Settlement Scheme 2020 to 31.03.2021
28 22 Dec 2020 Income Tax Bar Association, Lucknow Extend Time for filing ITR & Audit Report for A.Y 2020-21
28 22 Dec 2020 53 GST and Trade Associations 53 Associations requests Extension for GSTR 9, 9A & 9C
29 16 Dec 2020 Chandigarh Chartered Accountants Taxation Association Extend Income Tax & GST Return & Audit due dates
30 22 Dec 2020 Bhayander CA Social Group Request to extend Due date of Annual GST Return & Audit
31 22 Dec 2020 Luminaires Accessories Components Manufacturers Association Extend due dates for Tax Audit & Income Tax Return filing for AY 2020-21
32 22 Dec 2020 All Professionals, Tax Payers and Stakeholders Open letter for extension of Due dates under Income Tax and GST
33 22 Dec 2020 Punjab Accountants Association Extend due date for filing ITR & Tax Audit Report- AY 2020-21
34 22 Dec 2020 Bhayander CA Social Group Extend Income Tax Audit & ITR Due dates for AY 2020-21
35 23 Dec 2020 The Tax Bar Association, Odisha Extend due dates of Audit Reports, ITRs, GST Returns, VSV Scheme
36 21 Dec 2020 Sales Tax Bar Association, Delhi Extend Tax/TP Audit & ITR Due dates for AY 2020-21
37 23 Dec 2020 Direct Taxes Professionals’ Association Extend Income Tax, Companies & CGST Act compliance due dates
38 24 Dec 2020 ICSI Extend due dates of CFSS, LLPSS, Charge Forms, Meetings
39 24 Dec 2020 All Odisha Tax Advocates Association Extend due date for filing TAR/ITR/GSTR9/9A/9C
40 25 Dec 2020 BJP Economic Cell, Rajasthan Extend Income Tax, GST, LLP, Company Law due dates
41 23 Dec 2020 Hyderabad Chartered Accountants’ Society Extend Due date under GST and Income Tax
42 22 Dec 2020 A. P. Tax Bar Association, Vijayawada Extend date of filing of GSTR 9, GSTR 9C and IT returns
43 03 Jan 2021 National Company Law Tribunal Bar Association Representation for further extension of CFSS 2020
44 25 Nov 2020 Merchants Chamber of Uttar Pradesh Request for extension of Company Fresh Start Scheme 2020
45 04 Jan 2021 Adv. Anuj Bhatt Request to President to take Suo-Moto cognizance of GST Issues
46 03 Jan 2021 The Chamber of Tax Consultants Extend Income-tax due dates with humane approach
47 01 Jan 2021 WMTPA Highly Disappointing GST Audit Due Date Extension
48 01 Jan 2021 The A.P. Tax Bar Association, Vijayawada Extend due date of Form GSTR 9 and 9C for year 2018-19

More Under Income Tax


  1. Sunny John says:

    We, the citizens expect more responsible and proactive action of Government in the current situation as they are still in chains of the pandamic. As partners in nation building by paying tax, we have rights to get justice and also humanitarian compassion when we are broken. And that’s why we are pleading for extension of IT filing dates. Hope, the PM, FM and other authorities will consider the request of CA Association and take an early decision favourable to the people.



  3. K. C. Baheti says:

    Very good representation give to FM & PM and on that basis the govt. should consider the request immediately otherwise no use. Although it is correct but business man also take care to complete their books in time so the work can be finished in time.

  4. K. C. Baheti says:

    Very good representation give to FM & PM and on that basis the govt. should consider the request immediately otherwise no use. Although it is correct but business man also take care to complete their books in time so the work can be finished in time. Our responsibility is two-way. This should also be keep in our mind.

  5. Brahma Nand says:

    Government should immediately extend the due date of above mentioned compliances till 31st March 2021. Whole the country is fighting with COVID and North region is severely affected. These days there is cold wave and no body want to take chance to compromise with health by working extreme hard and till night as it was done in previous years to do the compliances before due dates.

  6. Y NARENDRA says:

    The people are not fully out yet, the bus facility is limited, LACKDODWN is fully operational from March 20th to June, the people are all just a little outside now, so time must be given,
    I hope our esteemed Nirmala Sitharaman will take a quick decision on this matter.

  7. Ramaswamy t s says:

    We need to be more responsible and proactive to Government. We, partners in nation building, must ensure timely accounts, audit, tax filing and ensure timely payment of taxes, instead of seeking time when government needs funds to tackle pandemic. No great job in seeking time. Be disciplined. Advise clients to be prompt. Use technology and remain updated at all times. Let us not be parasites to Government. Gain confidence of Honourable PM. Work smart.

  8. sathyanarayanna says:

    Good representation , which we chartered and tax association should fight unitedly to enable CBDT and CBIC to extend due dates . Still audits are still uncompleted in may unlisted and Firms ,LLP . So the CBDT should extend the time limit . Waiting for good news .

  9. ANIL RAICHURA says:

    Due to various factors which are beyond the controlof the assessees and CA the audit of accounts and filing of ROI are getting delayed. Hence the Govt. has to extend the dates of filing ROI as sought by the Association, which will be of great help to the tax paying public, who have suffered heavily due to the COVID – 19 pandamic.

    Extend must need .. Why CA association not filed case in Supreme Court ?.. IT & GST department only listen the language of Court !!!!!

  10. P G Mohan Sastry says:

    Very Good Representation Sir
    Hope our Beloved Finance Minister may certainly considred the request with humanitarian gound as our Country is facing lot of problems in all the fields. especially Tax Practitioners,Chartered Accountants are facing much difficulties with thin attendance in the offices due to Covid19. Let us hope for the best

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