Request for Extension of Income Tax Return & Audit Due Dates Filed with CBDT

The Nagpur Chamber of Commerce has submitted a request to the Central Board of Direct Taxes (CBDT) for a two-month extension on the due date for filing income tax returns for the A.Y. 2025-26. This request is specifically for taxpayers whose accounts require auditing. The chamber cites multiple, interconnected issues that have made it difficult for taxpayers and professionals to meet the current October 31, 2025, deadline. A primary reason is the delayed and staggered release of ITR forms and utilities by the CBDT. Key forms, like ITR-5, ITR-6, and ITR-7, were made available only in August 2025, leaving a shortened compliance window. Furthermore, frequent updates and revisions to these utilities have created a cycle of duplicated effort, as audits had to be re-validated with new schemas. The chamber also notes that the previous extension for non-audit returns to September 15, 2025, indirectly reduced the effective time available for audit cases, which typically begin after non-audit finalizations.

In addition to the technical and logistical challenges, the representation highlights several other factors compounding the issue. Persistent glitches on the Income Tax e-filing portal, including upload failures and validation errors, have created further delays. The period also faces overlapping compliance deadlines for GST, MCA filings, and other statutory requirements, placing a heavy burden on professionals. The Institute of Chartered Accountants of India (ICAI) has also introduced a new, vertical format for non-corporate financial statements, which requires additional time for adaptation. Lastly, the upcoming festival season (Navratri, Dussehra, Diwali) is expected to disrupt work across various regions, reducing the effective working calendar. The chamber argues that without an extension, the pressure to meet the tight deadline will lead to an increased risk of errors, potential penalties, and burnout among professionals, which could undermine the ethos of voluntary tax compliance. They propose a new due date of December 31, 2025, for audit cases and November 30, 2025, for the filing of audit reports.

NAGPUR CHAMBER OF COMMERCE LTD.
73, Central Avenue, Seva Sadan Square, Nagpur – 440 018 Ph. : 2720164 Email : nccIngp@gmail.com

To
The Chairman,
Central Board of Direct Taxes (CBDT),
Ministry of Finance, Government of India,
North Block, New Delhi — 110001

Sub.: Representation for Extension of Due Date for Filing of Income Tax return for audit assessee Reports for AY 2025 — 2026 considering Practical Compliance Challenges & upcoming festivals

Hon’ble Sir,

We, Nagpur Chamber of Commerce Limited, was formed almost 70 yrs back and is one of the oldest active organizations of the traders & business fraternity not only of Nagpur but of entire Central India. The Chamber is member of FICCI and serving to almost every traders & business entity of Central India.

We respectfully submit this urgent representation seeking an extension of at least two months in the due date for filing of Income Tax returns for the taxpayer whose accounts needs to get audited for AY 2025-26. We are seeking extension in due date of filing of return since as per provision of section 44AB the due date of filing of Audit report is one month prior to the due date specified as per section 139(1) of the Income Tax Act, 1961 as such the extension of Income Tax return filing due date is requested which would automatically results in extension of due of filing of the audit reports & other reports applicable to the taxpayers covered u/s. 44AB or any other provision wherein the due date is linked with the return filing due date.

This request is primarily based on the significant challenges, coupled with systemic issues highlighted in recent representations by various professional and trade bodies.

1. Delayed Availability and Multiple Revisions of Audit and ITR Forms and Utilities:

Traditionally, ITR utilities are made available in April, giving taxpayers and professionals ample time to plan. This year, however, the rollout has been staggered and delayed. The ITR-5 for partnership firms, LLPs, AOPs, and trusts was released as late as 08th August while ITR-6 and ITR-7 used by companies and trusts were released subsequently. Even the forms that were released earlier (ITR-2, ITR-3) underwent further updates at the end of July & August, forcing professionals to redo their work and wasting precious days.

The TAR utility and schema were released in a staggered manner this year. The updates / changes were introduced over a period of time, causing uncertainty and compliance difficulties.

The CBDT notified amendments to Form 3CD via Notification No. 23/2025 dated 28.03.2025, effective 01.04.2025. The updated TAR utility and schema were released only in mid-July 2025, with further patches / updates issued in late July and August 2025.

Frequent version changes in the utility resulted in duplication of efforts, as audits already completed had to be revalidated with new schema releases.

The staggered release of utilities has left a substantially shortened compliance window for taxpayers who are subject to audit. For instance, ITR-5, ITR-6 and ITR-7 utilities, which cater to firms, companies and trusts, were released only in August 2025. By this time, more than half of the compliance window had already lapsed. Taxpayers under audit typically require considerable lead time to compile financial statements, carry out statutory audits, reconcile data across multiple reporting systems (GST, TDS, SFT, etc.), and prepare disclosures mandated under the Income Tax law. The late release of utilities means that instead of having the usual span of three to four months, professionals are now left with only a few weeks to complete these tasks, making it practically impossible to meet statutory deadlines without compromising on quality and accuracy.

2. Extension of Non-Audit ITR Deadline : The due date for the filing of the ITR in case of non-audit were already extended to 15th September 2025. This extension indirectly reduces the effective time available for audit assessee, since the filing season for audits generally begins in earnest only after non-audit return finalisations. The file of non-audits assessee took substantial time since the new ITR forms for AY 2025-26 introduce more detailed disclosure requirements, which required additional time and effort to complete accurately.

The Taxpayers with complex income profiles, including capital gains, foreign assets and business income, face significant challenges due to the late release of ITR-2 and ITR-3 utilities in mid-July. The Taxpayers have limited time to compile financial data, ensure accuracy of computations and file returns. There were issues with intra-head adjustment of short-term and long-term capital losses which lead to incorrect tax computation as such taxpayers & professionals were investing considerable time in manual reconciliation to avoid potential errors. Further more the discrepancies and technical issues have been noted with the Annual Information Statement (AIS) and Tax Information Summary (TIS) data. There were instances wherein differences have been observed between AIS and TIS data for the same Permanent Account Number (PAN) when downloaded simultaneously. There were multiple instances where AIS and TIS data could not be downloaded despite repeated attempts. These issues caused inconvenience and delays in tax compliance both by the taxpayer & professionals.

3. Persistent Portal Glitches: Upload failures, validation errors, and data mismatches in the Income Tax e-filing portal remain unresolved, posing significant risks to timely and accurate filing. Although the e- filing portal has improved in recent years, systemic issues persist during peak filing seasons. Assessee and tax professionals are facing frequent schema updates, validation errors, and portal downtime. Each schema update requires taxpayers to revalidate and sometimes re-enter information, causing duplication of effort and wastage of already scarce time. Additionally, users have frequently encountered slow portal responses, error messages while uploading returns, and occasional rejections without adequate diagnostic information. These issues not only disrupt workflow but also cause anxiety among taxpayers who fear penal consequences for delayed compliance.

4. Overlapping Compliance Deadlines: Concurrent deadlines under GST, MCA filings, and ICAI’s revised reporting formats increase the burden on professionals, making the existing timelines impractical. The compliance calendar for businesses and professionals is heavily crowded during the months of July to October. Alongside Income Tax compliances, taxpayers are required to meet GST filing obligations (monthly and quarterly returns), company law compliances including filing of annual returns and financial statements with MCA, and sector-specific regulatory submissions. For entities subject to statutory audit, auditors must simultaneously complete tax audits, statutory audits under the Companies Act, and GST audits, often for the same financial year. For most charitable entities, they also need to file applications for renewal of their s.12A and s.80G registration/approval by 30th September 2025. This overlap results in excessive pressure on both taxpayers and professionals, leading to undue stress, errors in filings, and avoidable disputes later.

5. Risk of Erroneous Filings and Litigation: The pressure to comply within tight deadlines contributes to increased errors, subsequent revisions, appeals, and litigations, burdening both the taxpayers and the department. The latest ITR forms and audit reports require extensive disclosures. While these requirements are welcome from a transparency standpoint, they substantially increase preparation time and require collation of data from multiple systems. They need to be filled in properly, as incorrect filling in can result in unwarranted demands. For corporates, in particular, the new reporting requirements in ITR-6 and Form 3CD necessitate coordinated efforts between the finance, audit, legal, and compliance teams. With utilities released late, the time available for inter-departmental reconciliation and audit review has become severely constrained.

6. Revised Format of Financial Statements for Non-Corporate Entities: The Institute of Chartered Accountants of India (ICAI) has introduced a revised format for financial statements of non-corporate entities, effective from FY 2024-2025. The new format adopts a standardized vertical layout, replacing the traditional “T-form” presentation, which requires additional time for adaptation, review and reconciliation. This change may extend the timeline for finalization and filing of financial statements, necessitating efficient planning and execution of financial reporting processes since this being first year for the non corporate Traders / business entities to get adopted to such major changes brought in by the ICAI.

7. Other Issues: Festivals: India’s diverse festivals, such as Navratri, Durga Puja, Dussehra, and Diwali, lead to work disruptions at varying times across regions, affecting businesses and government departments. This results in a reduced effective working calendar, particularly impacting sectors like retail, manufacturing, logistics, and e-commerce, which experience increased workloads during festive seasons. During the festival the paid employees & accountants also go for holidays to their native place which further results in hardship to the traders / taxpayers in fulfilling the requirements of the professional for completion of the audit work. Consequently, taxpayers and professionals face challenges in completing the timely preparation, review, and filing of Audit Reports.

In the event if there is no extension the impact of such non relief will be :

a. Increased probability of filing errors and omissions.

b. Cascading risk of penal proceedings and interest.

c. Professional burnout and compliance fatigue.

d. Erosion of voluntary compliance ethos.

Appeal for Extension: We respectfully request that you consider the challenges and complexities outlined above and grant an extension of the due date as requested as under :

This would provide necessary relief and enable taxpayers and professionals to comply with the statutory requirements efficiently.

An extension will significantly alleviate the hardships faced by traders, taxpayers and tax professionals, promote accurate and timely compliance, and maintain the mutual trust fundamental to India’s tax administration.

We appreciate the CBDT’s history of receptive and pragmatic governance and trust that this representation will receive sympathetic and timely consideration.

Yours faithfully,

Kailash Jogani
President — Nagpur Chamber of Commerce Limited

Date : 17^th September 2025.
Place : Nagpur

Cc.: The Hon’ble Prime Minister of India, PMO Office, New Delhi The Hon’ble Finance Minister, Ministry of Finance, New Delhi