Request for Extension of Due Date for Submission of Non-Tax Audit Report

The Karnataka Taxpayers Association (Registered), Shimoga, has formally requested the Ministry of Finance and the CBDT to extend the due date for submission of Non-Tax Audit or Non-Audit Financial Compliance reports currently set for 15 September 2025. The Association, comprising tax professionals and business stakeholders, highlights multiple difficulties making timely compliance unfeasible.

Key concerns include the delayed release of final utilities, templates, and audit formats—many of which underwent multiple changes—leaving insufficient time for accurate reconciliations and reviews. Technical glitches in filing portals such as session timeouts, upload failures, and slow responses have further hampered progress, particularly for users in remote areas.

Additionally, delays and mismatches in external data (such as AIS, Form 26AS, or third-party statements) are causing extended verification processes. The situation is further complicated by overlapping statutory deadlines for tax audits, GST filings, and other financial reporting, straining the capacity of practitioners—especially smaller firms. Recent updates in disclosure norms and audit formats also require time for adaptation and implementation.

Similar requests have been made by other professional bodies like the Bombay Chartered Accountants’ Society, Gujarat Chamber of Commerce & Industry, and Chandigarh CA Taxation Association, all citing comparable operational challenges.

The Association has respectfully urged the authorities to extend the current due date to a more practical timeline, ensuring proper reconciliation, verification, and submission without compromising the quality of compliance.

Representation is as follows:

Subject: Request for Extension of Due Date for Submission of Non-Tax Audit Report as on 15-09-2025 Difficulties Being Faced.

Respected Madam / Sir,

We, the Karnataka Taxpayers Association (Registered), Shimoga, are a voluntary association of taxpayers, chartered accountants, tax practitioners and business persons in the State of Karnataka. Our aim is to promote compliance, taxpayer education, and making tax administration practicable, transparent and efficient. Over the years, we have submitted representations to your good offices on matters of mutual concern between taxpayers and the tax administration, always with a view to ensuring fairness and to avoid unintended hardship.

2. We wish to draw your kind attention to the significant difficulties being faced by taxpayers and tax practitioners in concluding the Non-Tax Audit / Non-Audit Financial Compliance (or “Non-Tax Audit” meaning the audit or review of accounts by statutory/non-statutory checks not covered under tax audit, or audit‐like verifications, or analogous compliance) as on  15-09-2025. Several pressing issues have made it impracticable to meet the existing deadline. Without an extension, the quality of reporting, verification, reconciliation, and hence overall compliance, will be compromised. The key difficulties are as under:

Difficulties Experienced

1.Delay in Release / Availability of Utilities, Forms & Templates.

The final versions of required utilities, non-tax audit formats, digital templates, reconciliations tools have been released late or have required multiple amendments. This has reduced the effective time available for completing reviews, reconciliations, verifications etc.

2. Technical Glitches in Portals / Systems.

The electronic portals used for submitting financial data and related forms are encountering intermittent failures, slow response, session time‐outs, upload errors. This hampers submission especially for those with large volumes of data or in remote / less connected areas.

3. Mismatch & Delay in External Information / Statements.

Key external data required for reconciliation (for example, third party statements, bank statements, utility statements, AIS, Form 26AS or their equivalents for non‐tax audit use) are delayed, incomplete, or mismatched. This necessitates extra time for verification and correction.

4. Overlapping Statutory Obligations & Compressed Time Frames

Many taxpayers / firms are simultaneously subject to other statutory / regulatory deadlines (e.g. tax audits, GST, financial reporting, other sectoral audits). The compressed calendar leaves little flexibility to allocate human resources, especially for smaller firms or individual practitioners.

5. Recent Changes in Norms or Formats.

Where new formats, disclosures, or audit checklist items have been introduced (financial statements presentation, note disclosures etc.), adjusting to them takes additional time (learning, data collation, restatement etc.).

3. Given the above, our Association believes that meeting the due date of 15-September-2025 for conclusion of non-tax audit / analogous compliance is unrealistic for many.

4. Other Associations (e.g. BCAS, GCCI, CCTAX etc.) have made similar representations recently with respect to extension of ITR / Tax Audit deadlines, citing these kinds of issues — delayed utilities, portal glitches, mismatch of AIS / Form 26AS data, new formats etc. These are being considered in the public domain as genuine hardships. (Refer Examples: Bombay Chartered Accountants’ Society’s representation; Gujarat Chamber of Commerce & Industry’s representation; Chandigarh CA Taxation Association’s request.)

In view of the above, Karnataka Taxpayers Association (R), Shimoga humbly requests that your esteemed office kindly:

• Extend the due date for concluding Non-Tax Audit / Non-Audit Financial Compliance as on 15-09-2025 to any other date deemed appropriate, so that taxpayers and practitioners have sufficient time to complete reconciliation, audit-review, corrections, and submissions without compromising quality.

We remain hopeful that this submission will receive your kind consideration and empathetic action.

Thanking You.

Yours faithfully,
Zafarulla Sattar Khan

Chartered Tax Practitioner
Founder State President
Karnataka Taxpayers Association ( R )