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Government of India has extended Due dates for various Statutory compliance under Income Tax Act,1961 through ‘THE TAXATION AND OTHER LAWS (RELAXATION OF CERTAIN PROVISIONS) ORDINANCE, 2020‘, which came in pubic domain on 31st March 20 and other notifications issued from time to time up to 31st July’2020.
I have tried to complied all the Key compliance falls during the period March 2020 to December 2020 alongwith detailed analysis of relaxation given from various legal Consequences, which are otherwise applicable under Income Tax Act, 1961.
Statutory Compliances under Income Tax Act |
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S. No |
Nature of Obligation / Particulars |
Form / Challan |
Frequency |
Original Due Date |
Extended Due Date |
Original consequence like Interest / penalty / Fee |
Revised consequence like Interest / penalty / Fee |
Extension & Relief for TDS & TCS related Compliances:- |
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1) |
Due date for deposit of TDS / TCS for the month of: – |
Challan No. ITNS 281 |
Monthly |
1) Interest @ 1% / 1.5% p.m. or part thereof as the case may be u/s 201(1A) & 206C (7);2) Penalty u/s 221 or 271C/CA up to TDS / TCS amount;3) Punishable with rigorous Imprisonment for (Mini. 3 months or Maxi. 7 years) with fine u/s 276B/BB |
1) For the payments due before 20th March’20 or after 30th June’20, intt. will be payable @ 1%/1.5% p.m. or part thereof and penalties & prosecution is also applicable2) For all other payments due after 20th March’20 and before 30th June’20 interest @ 0.75% p.m. or part thereof and all penalties & prosecution is waived off if Taxes paid on or before 30th June’2020. |
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Febuary’2020 |
7th March’20 |
7th March’20 |
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March’2020 |
30th April’20. |
30th April’20 |
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April, 2020 |
7th May’20 |
7th May’20 |
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May’2020 |
7th June’20 |
7th june’20 |
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June’2020 to December’2020 |
7th of following Month |
7th of following Month. |
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2) |
Due dates for filing of Quarterly statement of TDS / TCS deposited for the quarter ending |
Quarterly |
1) Late Fee u/s 234E of Rs. 200 per day & up to the amount of TDS deducted / TCS collected.2) Penalty u/s 272A @ Rs. 100 per day and maxi. up to the amount of TDS deducted / TCS collected.3) Penalty u/s 271H mini. 10,000 to maxi.1,00,000. |
1) Not leviable i.e. Nil. |
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March 31, 2020 |
(TDS)24Q, 26Q, 27Q |
31st May 2020 |
31st July 2020 |
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June 30, 2020 |
31st July 2020 |
31st March 21 |
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September 30, 2020 |
31st Oct. 2020 |
31st March 2021 |
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March 31, 2020 |
(TCS)27EQ |
15th May 20 |
31st July 2020 |
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June 30, 2020 |
15th July 20 |
31st March 2021 |
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September 30, 2020 |
15th Oct. 2020 |
31st March 2021 |
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3) |
Furnishing of challan-cum-statement for tax deducted u/s194-IA (Purchase of property >50 Lacs) for the month of: –February’ 20 to April’ 20May’ 20 to Nov.’ 20 |
26QB |
Monthly |
Payment to be made within 30 days from the end of relevant month. |
Payment to be made within 30 days from the end of relevant month. |
Same Interest, penalty & prosecution as mentioned in para 1 & 2 above except disallowance of expense. |
1) Interest will be charged @ 0.75% p.m. or part thereof only as discuss above if payment made before 30th June. Further, if statement for Feb.’20 to April’20 filed up to 31st July and for the period May’20 to Nov.’20 filed up to 31st March’21 then original consequences mention in para-2 is waived off but consequences of Para-1 will be applicable. |
4) |
A) Issuance of TDS Certificate in respect of salary paid and tax deducted during F/Y 2019-20 |
Form 16 |
Yearly |
15th June 2020 |
15th Aug. 2020 |
Penalty u/s 272A @ Rs. 100 per day and maxi. up to the amount of TDS / TCS deducted / Collected. |
Not leviable i.e. Nil |
B) Issuance of TDS certificates(other than salary) for the quarter endingMarch 31, 2020 |
Form 16A |
Quarterly |
15th June 2020 |
15th Aug. 2020 |
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June 30, 2020 |
15th Aug. 2020 |
15th April 2021 |
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September 30, 2020 |
15th Nov. 20 20 |
15th April 2021 |
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C) Issuance of Quarterly TCS certificates for the quarter endingMarch 31, 2020 |
Form 27D |
Quarterly |
30th May’20 |
15th Aug. 2020 |
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June 30, 2020 |
30th July 2020 |
15th April 2021 |
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September 30, 2020 |
30th Oct. 2020 |
15th April 2021 |
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5) |
Issuance of TDS Certificate for tax deducted under Section 194-IA in the month of: –January’ 2020 |
16B |
Monthly |
Within fifteen days from the due date for furnishing the TDS Returns. |
17th March 2020 |
Penalty u/s 272A @ Rs. 100 per day and maxi. up to the amount of TDS deducted. |
Not leviable i.e. Nil in all cases except Jan’2020. |
February’ 2020 & March’ 2020 |
15th Aug. 2020 |
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April’ 2020 to Nov.’2020 |
15th April 2021 |
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6) |
Due date for submission of Form- 27C (Part-I)Febuary’2020 |
Form No. 27C Part-II |
Monthly |
7th Mar. 2020 |
7th March 2020 |
Penalty u/s 272A @ Rs. 100 per day and maxi. Up to the amount of TCS collectible. |
Not leviable i.e. Nil in all cases except Feb.’ 2020. |
March 2020 to Nov. 2020 |
Within 7 days from the end of relevant month. |
31st March 2021 |
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Extension & Relief for other Income Tax compliances :- |
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1) |
Due dates for filing of income tax returns: – |
All ITR Forms |
Yearly |
1) Interest @ 1% p.m. or part thereof u/s 234 A/B respectively.2) Further, in case of belated return you are liable for late fee u/s 234F mini. 1000 to maxi. 10,000. |
No relief has been given for Interest & Late fee as otherwise applicable for the F/Y 2018-2019.For F/Y 2019-2020, interest u/s 234A will not charge from original due date if Self-Assessment Tax is < 1 lacs if ITR filed till 30th Nov. 20 and further, late fee is also not leviable in all cases. |
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Belated / Revised ITR for FY 2018-19 (AY 2019-20) |
31st March 2020 |
31st July 2020 |
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Original ITRs for FY 2019-20 (AY 2020-21) |
31st July2031st Oct.’20 |
30th Nov. 2020 |
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2) |
The last date for linking of PAN with Aadhaar. |
NA |
One Time |
31st Mar.’20 |
31st Mar.’21 |
PAN would be de-activated after 31st March’20. |
Not de-activated till 31st March’21. |
3 |
Due date for furnishing Audit report for F/Y 2019-20: –Tax Audit Report |
Form 3CA/ CB/CD |
Yearly |
30th Sept. 2020 |
31st Oct. 2020 |
In case of Tax Audit, liable for penalty @ 0.5% of the turnover or Rs. 1.5 lakh whichever is lower. |
Not Leviable i.e. NIL |
Audit Report of Trust |
Form 10 B |
30th Sept. 2020 |
31st Oct. 2020 |
In case of Form-10B, Exemption u/s 11 & 12 Not allowed. |
Exemption u/s 11 &12 available if filed within extended due date. |
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4 |
Due dates for making various investment / payment for claimingdeduction under Section 80C (LIC, PPF, NSC etc.), 80D (Mediclaim), 80G (Donation), etc. |
Yearly |
Falls during the period 20th March’20to 30th July’20 |
31st July’20 |
No deduction allowed during F/Y 2019-20 if not paid on due date. |
You can claim deductions during F/Y 2019-20 if paid before 31st July’2020. |
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5 |
Due dates for making investment/ construction/ purchase of Residential House, Bonds etc. for claiming roll over benefit / deduction in respect of capital gains under sections 54 to 54GB |
Yearly or Transaction wise. |
Falls during the period 20th March 2020 to 29th Sep. 2020 |
30th Sep.’20 |
No deduction allowed during F/Y 2019-20 if not paid on due date. |
You can claim deductions during F/Y 2019-20 if paid before 30th Sep.’2020. |
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6 |
A) Payment of 4th instalment of advance income tax for the A/Y 2020-21.B) Payment of whole amount of advance tax for the A/Y 2020-21 (under presumptive scheme of Section 44AD/ 44ADA) |
ITNS-280 |
Quarterly |
15th March 2020 |
15th March 2020 |
Interest @ 1% p.m. or part thereof u/s 234C |
Interest @ 1% p.m. or part thereof u/s 234C |
7 |
Instalments of Advance Tax for the Assessment year 2021-22 |
ITNS-280 |
Quarterly |
15th June 2020 |
15th June 2020 |
Interest @ 1% p.m. or part thereof u/s 234C |
Interest @ 0.75% p.m. or part thereof u/s 234C if paid before 30th June’2020. However, No Relief is given for Sep.’20 & Dec.’20 Quarter. |
15th Sept. 2020 |
15th Sept. 2020 |
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15th Dec. 2020 |
15th Dec. 2020 |
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8 |
Due date for furnishing of statement of financial transaction (AIR) as per section 285BA (1) read with rule 114E for F/Y 2019-20. |
Form No. 61A |
Yearly |
31st May’20 |
31st Mar.’21 |
Penalty u/s 271FA @ Rs. 500 per day. |
Not Leviable i.e. NIL |
9 |
1) For I. Tax DepartmentThe time limit for thei) completion of proceedingsii) passing of any orderiii) Issue of notice,iv) intimation,v) notification,vi) approval /sanction orderby any authority, Commission, Tribunal & other under the provision of Income Tax Act. |
Expiring between 20th March’20 to 31st Dec.’20 |
31st Mar.’21 |
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2) For Assessees The time limit for thei) filing of an appeal / replyii) furnishing of any report or documentsiii) filing of Return / statementsiv) or any other records by any person under provision of Income tax Act. |
Expiring between 20th March’ 2020 to 31st Dec. 2020 |
31st March 2021 |
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10 |
The time limit for payment under the Direct Tax Vivad Se Vishwas Act, 2020. |
Form-1 Form-2 |
One Time |
31st March 2020 |
31st Dec. 2020 |
10 / 5 % Additional Charges. |
No Additional Charges will be levied if payment made up 31st Dec.’2020. |
11 |
Verification of ITRs for the A/Y 2015-16, 2016-17, 2017-18, 2018-19 and 2019-20 which are pending due to non-filing of ITRVForm. |
ITRV |
Yearly |
120 days from date of uploading the ITR |
30/09/2020except the cases, where Department has already taken action as per Act. |
ITR is/can be declared Non-est in law i.e. do not exist, thereafter, all the consequences for non-filing ITR, as specified in the Income-tax Act, 1961 will be applicable. |
ITR will not be declared Non-est in law and consequences for non-filing ITR, as specified in the Income-tax Act, 1961 will not be applicable. |
12) |
Application by Exiting trust / societies / other entities for Unique Approval / Registration number (UAN / URN), which are currently approval/ registration/ notification under u/s 10(23C), 12AA, 80G. |
Not yet notify |
One Time and after that once in Five Year |
1st June’20 to 31st Aug.’20 |
1st Oct.’20 to 31st Dec.’20 |
Exemption u/s 11 & 12, 10(23C) are not available and Approval u/s 80G will also withdraw after 31st Aug.’20 |
Exemption u/s 11 & 12, 10(23C) will be available and approval u/s 80G is also valid till 31st Dec.’20. |
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Can you please share the basis on which you mentioned that Due Date of TDS Return filing for the QTR 2020-21 Q1 is 31st March’2021??