Chartered Accountants’ Association Ahmedabad requested that CBDT shall exercise the discretionary powers vested in it under section 119 of the Act, by extending due date of 30th September, 2019, to ameliorate the difficulties faced by the assessees on account of no default on their part, by extending the due date for filing the income tax returns for a one and half month upto 15th November, 2019, on account of the delay in notifying the forms and utilities.

Chartered Accountants Association, Ahmedabad

Hon. Smt. Nirmala Sitharaman
Union Minister of Finance
Ministry of Finance,
Government of India, North Block,
New Delhi — 110 001
Email: fmo@nic.in

Respected Madam,

Re: Request for extending due date for submitting Tax Audit Reports/related

1. About Associations

The Chartered Accountants’ Association Ahmedabad (CAA) was established as a voluntary organization on 15th December, 1951. At present, CAA has about 1425+ members not only from Ahmedabad but from all over the country.

The main objects of CAA are: To spread education in the science and art of Accountancy and all its branches and in particular in relation to matters of professional interest to Chartered Accountants such as Taxation, Audit, Finance, Commercial legislation, Computer Science, etc.

To better equip Chartered Accountants to enable them to discharge their obligations towards the advancement or promotion of trade, commerce and industry thereby leading to economic prosperity for the benefit of the entire community.

To provide continuous education to its members in particular and tax paying public at large. It has always been the main concern at CAA to see that members keep pace with fast changing times.

With the opening of economy and globalization, CAA has also taken up plans to educate the members on the latest topics of E-Commerce etc. CAA is equipped with a vast library which includes the latest books on wide range of subjects as well as electronic database of case laws on direct taxes.

2. We appreciate and complements to Finance Ministry for the government announcement of corporate tax reduction from 30 to 22 per cent for domestic companies and 15 per cent for new manufacturing companies, in a big measure to boost growth and investment. This is a great move which will firmly revive growth and investment. Our compliments to FM Nirmala Sitharaman for this bold but most needed move.

3. We appreciate the commitment and efforts of Govt. to re-orient tax administration to make it pro-tax payer and for providing ease of doing business. This year Central Board of Direct Taxes [CBDT) has made substantial delays in notifying the ITRs forms and I.T. return preparation software followed by the frequent amendments in schema and validation of rules creating the chaotic situation for assesses and tax professionals, which forces us to request for extension of due dates for filing the ITRs. Because it is assessee who would have to get agonized and face the consequences of delay in filing return, on account of delay in providing platform for online filing of returns by the CBDT.

4. Most of tax-payers are now mandatorily required to file their returns of income online, either using the return preparation software developed by the third parties or made available by the CBDT. Whenever, if there is change in return/Schema/Validation rules, it requires up dating and providing afresh utility on e-filing portal of the dept. as well as validation of software by the private developers. which in turn is required to be explained and understood by the users and sometimes requires collection of further information/data from the tax-payers by the tax professionals.

5. For the A.Y 2019-20, CBDT has changed the ITR forms necessitating the changes in software/utilities for online filing of returns in mid of the years from time to time.

6. Though, CBDT has extended the due date for filing income tax returns from 31st July to 31st August 2019, in cases of tax payers who are liable to file their income tax returns by the said due date (vide order-F. No. 225/157/2019/ITA.11). The extension of due date 31st July 2019 also necessitates the extensions of due date of 30th September, 2019, which is the due date for filing the return of income for the company, persons (other than company) whose accounts are required to be audited under this Act or under any other law for the time being in force, or a working partner of a firm whose accounts are required to be audited. In these cases assessees are required to furnish voluminous data in form 3CD, which in turn is required to be tax audited and uploaded on website of dept. followed by furnishing of ITR forms. I. T. return preparation software in cases ITR 3,5,6 & 7, applicable to tax audit returns, have been provided between dates 6-8-2019 to 19-08-2019.

7. Minimum additional time gap of 2 months provided in the law between both the due dates is compressed to only 30 days [ i.e. from 1st September to 30th September, 20191 due to non-extension of due date of 30th Septemeber, 2019.

From the historical due dates charts provided in I.T. Act, it can be observed the since A.Y 1989-90 to A.Y 1996-97 the legislature has given an additional time of 2 months to assesses (other than companies) who are required to get their books of accounts audited, than the assessees deriving income from Business & Profession & who are not required to get their books of account audited. From A.Y 2001-02 to 2007-08 the additional time limit given to company and assessees whose accounts are required to be audited is kept at 3 months.

8. From A.Y 2008-09 onwards, although, the due dates for filling return of income are advanced from 31st October to 30th September, but, minimum additional time limit of 2 months is provided in case of assesses who are required to get their books of account audited, than those who are not required to get their accounts audited.

9. The CBDT ought to have paid heed to the repeated directives of various High Courts and similar requests made by the stake holders in past, and could have notified the amended forms made applicable with effect A.Y. 2019-20 well in advance, before commencement of the relevant assessment year i.e. 1st April, 2019, instead of mid of the assessment year.

10. Gujarat High Court, in order dated 22nd September, 2014 in the case of All Gujarat Federation of Tax Consultants V. CBDT [SCA No.12656 of 2014] observed that any introduction or new utility/software with additional requirement in the middle of the year ordinarily is not desirable. Any change unless inevitable can be planned well in advance. Keeping in focus such comprehensive process re-engineering may not result in undue hardship to the stake holders.

11. It is requested that CBDT shall also exercise the discretionary powers vested in it under section 119 of the Act, by extending due date of 30th September, 2019, to ameliorate the difficulties faced by the assessees on account of no default on their part, by extending the due date for filing the income tax returns for a one and half month upto 15th November, 2019, on account of the delay in notifying the forms and utilities. Otherwise, it is the assessees who would have to face the consequences of not filing the returns in time.

12. Though, due to delay in notification of forms, CBDT has extended the due date for filling return of income from 31st July to 31st August in case of assessees, who are not required to get their books of accounts audited. Non extending the similar relief to the cases, where due date of filing Tax Audit Report & ITR form falls on 30th Sept. 2019 would be unjustified and cause severe hardship to these assessees.

13. Further, this year rain God has blessed the whole of India in abundance. The heavy rains have been continuing in whole of Gujarat till date, resulting into flood situation in various parts and disruption of normal life & business activities. Non extension of due date will cause lot of hard ship to assessees.

14. Regarding furnishing of details for corporates in Schedule SH-1 consists of details/information relating to all shares holders consists of 3 sheets and Schedule AL-1 consists of 10 different sheet for all historical data. This is the first time information/details asked for. Details like all historical data of Fbced Assets/shareholders etc. need huge time. In view of time constraint and schema finalised very late it is being required to make this details option for this year which will help companies and professionals to complete submission of returns on time.

15. We look forward to your compassionate response.

Thanks & Regards,
Yours Truly,

FOR CHARTERED ACCOUNTANTS ASSOCIATION AHMEDABAD

(CA ANAND SHARMA)
President

(CA RAJU SHAH)
Chairman L & R (Direct Tax) Committee

Dated: 20.09.2019

Copies to: (Sir, for kind perusal and favorable action)

1. Hon. Revenue Secretary,
Ministry of Finance
128-A, North Block, Secretariat,
New Delhi – 110001
Email: rsecy@nic.in
3. The Joint Secretary,
TPL-3 CBDT[TPL Division]
North Block,
New Delhi
2. The Chairman
Central Board of Direct Taxes,
Ministry of Finance,
North Block, Parliament Street.
New Delhi – 110001
Email: chairmancbdt@nic.in
4. Pr. Chief Commissioner of Income Tax, Gujarat (CCA)
Aayakar Bhavan,
Ashram Road,
Ahmedabad-380009

Download Above Representation in PDF Format

Details of Other Representation

S. No. Dated Submitted by Link
14. 23.09.2019   Cuttack Tax Bar Association Extend due date for filing of Tax Audit Report and ITR: CTBA
13. 23.09.2019 Sales Tax Bar Association Request for extension of due date for filling ITR and Tax Audit Reports
12. 16.09.2019 Institute of Chartered Accountants of India Extend due date for filing tax audit reports and related ITR: ICAI
11. 19.09.2019 The Punjab Accountants Association Extend due date for filing audited Income tax reports / Returns
10. 16.09.2019 Western Maharashtra Tax Practitioners’ Association Extend due date for filling tax audit reports & related Income tax returns
9. 17.09.2019 District Taxation Bar Association (Direct Taxes), Ludhiana Extend last date of filing of ITR & Tax Audit Reports to 15.11.2019
8. 16.09.2019 Tax Bar Association, Jodhpur Extend due date for filing Tax Audit reports and ITR to 30 November 2019
7. 16.09.2019 The Chamber of Tax Consultants Extend due date to file income tax return and tax audit report
6. 13.09.2019 All India Federation of Tax Practitioners Extend due date to file ITR & tax audit reports by one month
5. 11.09.2019 All Gujarat Federation of Tax Consultants Extend Tax Audit and related ITR Filing Due Dates
4. 19/08/2019 BCAS and 4 Others Representation on Income Tax and GST Issues faced by taxpayers
3. 13/08/2019 Goods & Services Tax Practitioners Association of Maharashtra Extend GST, Income Tax and other due dates falling in Aug & Sep 2019
2. 10/08/2019 Karnataka State Chartered Accountants Association Extend Due Date for Filing of Income Tax and GST Returns
1. 18/07/2019 Tax Bar Association, Jodhpur Extend due date for filing of Income-tax returns to 30th Sept 2019

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92 Comments

  1. samunder singh lodha advocate says:

    GST se laker sabhi date last hi hoti hai gst se kam bahut bada diya hai es karan se probleme aa rahi hai… i am request dete extended ………..any days

  2. Mohammed Rafijul Hoque says:

    The respected F.M and CBDT should extend due date at least upto 15/11/2019 as there is festival of Durgostav and Auditees are coming late.

  3. Dharmendra Sharma says:

    Kehna to nahi chahta par madam arun jaitley se kuchh seekh leni chahiye..Kabhi bhi nahi suni apne karyakaal me..Last hours tak tention diye rehte the..Hum bhi nagrik h apna farz nibhate h..Aapse ummeed h aap samjhenge takleef ko Dhanyawad..

  4. SANJAY KUMAR says:

    Respected F.M. Madam, Please allow the applications made from various associations from all over the country for extension of due date for filing ITR & Audit Report from 30th Sept..2019 to 15th Nov.2019 as all countrymen are suffer from natural calamity an act of god.

  5. DINESH LUTHRA says:

    Respected Madam..

    Please extend the due date for filing of tax audit report for AY 2019-20…..from 30 September to 30 November 2019…..please consider our request….

  6. Anthony says:

    With due respect i request you to extend the Due date for Tax Audit return up to 30.11.2019.
    Plzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzz Ma’am.

  7. Gyan Kularia says:

    Respected FM Mam,
    Yadi aaplo date extend nahi karni hain to, kripya yahi clear kar dijiye ki No EXTENSION. Aaj ki halat to bahut hi Kharab Hain. Jo bhi karna hoga uske like sabhi khud to taiyar to kar lenge. Yadi ekdum last me extention denge tab tak to kaffi kuch galat ho chuka hoga. Sirf itna nivedan jaroor hain jo bhi decission aap lo kripya aaj hi suchna dejiyega. Dhanyawad

  8. SANJAY AGRAWAL says:

    Respected mem please extend due date of Tax audit report we are in very worst conditions if you announce today we will be able to do work with relex mind please understand whole country’s problem we are suffering mind sickness so please do earlier

  9. azhar says:

    dear madam kindly consider the request for extension for tax audit from sept 30 to nov.30. Nothing will happens if you extend the date. Almost all the state association presented the request representations giving genuine reasons, but still you are not considering the request. So kindly extend the date today mam. thanks

  10. HSV BABU says:

    Dear FM Mm, Please allow us to little breath and for little relaxing atleast to give some time with our family for forthcoming festivels..Ofcourse we are also working as part of the government and on behalf. Give us little relaxation by extending TAR filing date till 30th November 19. Every year this subject is CRUSHING US. plz understand the practicle problems Mm.

  11. Ravi Shrivastava says:

    Respected mem please extend due date of Tax audit report we are in very worst conditions if you announce today we will be able to do work with relex mind please understand whole country’s problem we are suffering mind sickness so please do earlier

  12. ANURAG says:

    MUJHE LAGTA HAI IS SE JYADA GHAMAND AUR BESHARMI AUR KUCH NAHI HO SAKTA HAI KI PURA DESH REQUEST KAR RAHA HAI AUR CBDT KE KAAN ME JOON TAK NAHI RENG RAHA. KAM SE KAM YE TO KHA DO KI DATE EXTEND NAHI HOGA TAAKI HAM SAB RAAT DIN GADHO KI TARAH KAAM KAR SAKE.

  13. Arshad Husain says:

    Bahut dukh hua itne garhman logon ne request ki uske bad bhi koi eik reply bhi MADAM ne nahi diya.

    isliye subse winamr niwedan hai Bhai ab request karna chor do.

  14. Mohammed Gous Pasha says:

    Respected Madam..

    Please extend the due date for filing of tax audit report for AY 2019-20…..from 30 September to 30 November 2019…..please consider our request….

  15. balwinder singh says:

    आदरणीय मित्रो कृपया काम पर लग जाएं ।अब कोई ऑडिट डेट एक्सटेंशन के लिए प्राथना पत्र न दें और न ही गिडगिडाएँ । अब बात साफ हो गयी है ,कि जितनी भी संस्थाओ ने प्राथना पत्र श्रीमती निर्मला सीतारमण जी ,इनकम टैक्स डिपार्टमेंट को दिए हैं ,उसके बाद भी अभी तक ऑडिट डेट को बढ़ाने का कोई ऐलान नहीं किया गया । और फेक मेसेज पर इनकम टैक्स डिपार्टमेंट का ट्वीट तुरंत आ गया । इस से साफ़ है कि चार्टर्ड अक्काउंटैंट्स ,टैक्स एडवोकेट्स और प्रोफेशनल अक्काउंटैंट्स अपना काम करते रहे ,और अगर किसी क्लांइट की रिटर्न नहीं फाइल हो पाई ,तो कुछ सोचने की जरुरत नहीं ,गलत रिटर्न नहीं फाइल करनी ,पेनल्टी ,जुरमाना सब हम अपनी जेब से भरें ,और उसकी रसीद संभल कर रखें ।

  16. KALPESH M. TRIVEDI says:

    Respected F.M. Madam, Please allow the applications made from various associations from all over the country for extension of due date for filing ITR & Audit Report from 30th Sept..2019 to 15th Nov.2019 as all countrymen are suffer from natural calamity an act of god.

  17. Kalpesh M Trivedi says:

    Respected F.m. please allow the application from various tax practioner associations all over india regarding extension Of due date for audit and submission of itr for a.y. 2019-20.

  18. PRAKASH YADAV ADVOCATE says:

    DEAR MADAM JI, PROFESSIONAL ARE HELPING TO COLLECT TAX FROM CLIENT AND DEPOSIT IT IN THE TAX DEPARTMENT, IF THE DATE WILL BE EXTEND THEY WILL BE RELAXED AND WILL DO THEIR WORK WITHOUT TENSION.

  19. Mohammed Rafijul Hoque says:

    This is a humble request to extend due date upto 15.11.2019 for Tax Audit, Income Tax Return Submission for tax audited assessees. Regards.

  20. A.Sivakumar says:

    Respected Madam
    Please extend the date for filing TDR as we have severe shortage of accounting people and we do not have any other interest .Please extend it at least for a month say upto 30-10-2019

  21. Pravin says:

    Madam,
    Pl for God sake extend the date to 30 Nov 2019.In view of the change in entire assessment process, a quality audit report will help in framing correct assessment . Any work done in hurry by burning mid night oil is bound to be full of mistakes.

  22. BALWINDER SINGH says:

    AFTER CLARIFICATION FAKE NOTIFICATION BY INCOME TAX DEPARTMENT ,THIS IS CLEAR INDICATION BY DEPARTMENT ,DATE OF AUDIT RETURNS FILLING IS NOT EXTENDING.

  23. ANIL VERMA says:

    PLS. ISSUE NOTIFICATION OF INCOME TAX TAX AUDIT DATE EXTEND
    ताकि मानसिक शान्ति मिले और बीमार होने से बच जाएँ

  24. Y G PARTHASARATHY says:

    There was six months time from the close of the financial year ended 31st March, 2019. Every year, they want extension of time for filing the ITR. This is not a good practice. The stake holders and professionals should ensure that they complete the exercise within the stipulated time and not ask for extension every year. This creates a bad precedent.

    1. naresh pant says:

      your this kind of comment figures out the fact that you have gone short of work. please try to respect the requests and sympathize yourself to the other people who are holding the same profession as you but have a stack full of work to do in the few days remaining.

  25. Jayesh Kumar Davey says:

    The additional work of matching data with GSTR-2A is also time consuming and challenging… given imposititions on genuine tax payers is worth considering in extending time limit to 30.11.2019.

    Even non tax audit firms are still pending for various reasons mentioned above so far.

  26. Sandeep Singhal says:

    Dear PM, Please extend the Last date of TAR atleast One Month due to GST Complication we were unable for TAX AUDIT on Time. Please announce earliest, By which can take the Time to My Child.

  27. Nikhil Vijay says:

    I requested to CBDT & Hon. Smt. Nirmala Sitharaman
    Union Minister of Finance please extend the tax audit & return date and announce as early possible
    Thanks

  28. Ramesh Kumar says:

    Madam Ji, Khuda ke leye hamari prathana sun lize aur audit return ki date extend upto 30-11-2019 kar dize aur aaj hi announce kar de taki hum log heart attack se to bachh sake, Thanks

  29. Aslam Khan says:

    How many pressure may suffer a tax payer before lying hospital, So please we request you to due date for filling of tax audit report and ITR from 30th Sep. 19 to 15th Nov. 19
    Thanks

  30. azhar says:

    dear extension needed very much sir. see sir one fake notification has come extended till 15.10.2019 we request them not to joke at this time we are in very much tension of this work load. Clients are coming now and tension started we are working till late night but not completing the task. Request not to message this type of fake notifications. we need till 30.11.2019 or 15.11.2019.

  31. Vinod Kumar Gupta says:

    In view of wide spread requests from various organisations of professional and tax payers with their genuine plight it is a sincere request to extend the date for filing of tax audit to 30/11/2019 as a matter of relief to professionals/tax payers.

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