Chartered Accountants Association , Surat has once made a representation to Finance Minister for Extension of time Limit for filing IT Return (44AB Audit Cases) / tax audit date for ay 2017-18 / due to Work related issues in GST which arise due to Due to the hasty implementation of GST.
CAAS has requested for tax audit due date extension for AY 2017-18 and also requested CBDT to issue a suitable notification order extending tax audit due date for ay 2017-18 notification alongwith extension of due date of Income Tax Reruns which were falling due on 30th September 2017
Text of the Representation is as given below-
Chartered Accountants Association, Surat
Ref: CAAS/Representations/2017-18/02, Date: 15/10/2017
To,
The Finance Minister,
Ministry of Finance, Government of India, 134, North Block,
New Delhi – 110001
Respected Sir,
Subject: Re: Extension of time Limit for filing IT Return (44AB Audit Cases) and Work related issues in GST
As you are well aware of our Organisation – Chartered Accountants Association, Surat (CAAS), we would cut-short to our representation, which requires an utmost and urgent attention. As a part of its objectives, Chartered Accountant’s Association, Surat, a non-profit organization, works for the betterment of Chartered Accountancy profession, more specifically with respect to softer issues like better working conditions and standards for members of Chartered Accountancy profession, through representation like this. The present representation concerns around the deteriorated working conditions and lowering of work quality standards due to haste by the government in implementing various laws, rules and procedures.
Our Representation:
1. Due to the hasty implementation of GST, it has jeopardized the routine work of tax audit as well as ITR filing. On one side CAs juggling with GST and Tax Audit, find it extremely difficult work, while on the other side, time devoted by the tax payers in resolving audit is also quite low, since all tax payers are busy in complying with the GST procedures. Tax Audits were to be completed by 30th September 2017, however due to GST, due date was extended by 1 month. This shows that your ministry is wellaware of the implications in dealing with a failed outsourced network – the GSTN. Also, regarding the various returns to be filed under GST laws, your department had advertised so much simplicity, coupled with the so-called push button softwares and GSP Services with API capabilities, that everyone thought, GST compliance would be simple and easy to comply. But that turned out to be a myth.
However, a looking at the figures of return filing by the Income Tax Assessees upto 30th September 2017, it can be inferred that approx 75% of Corporate Assessees and 50% of other auditable entities u/s 44AB are yet to file their Income Tax Returns and Audit Report, which they had been doing at the close of due dates every year.
However, the overall wastage of public time due to GST, in terms of total man-hours, man-week or man-month, could be seen from the above chart. In other words, due to the superfast GST, the train of Income Tax compliance is late by 2 month, out of which one month would be required to fulfil GST compliances, whereas the other for IT Audit. Change related to quarterly filing for entities with turnover less than Rs.1.50 Crores was although declared, but notified in mid October i.e. 13th October 2017, which is of literally no relief during the heavy audit compliance period of October 2017. Hence, unless additional time would not be granted to comply with Audit and IT Procedures, the assessee would have to suffer from penalty u/s 271B and interest u/s 234A of IT Act. Besides, due to hasty verification of financial information, there is an inherent risk in audit, that material mis-statement may go undetected, which would be detrimental to the interests of the revenue and the overall purpose of tax audits. Hence, for quality work we mandate sufficient time and extension of due date as per para 6 below.
2. Earlier in July – August 2017, due to heavy floods, tax payers from various parts of the country including Gujarat could not either start their audit work or even start their accounting work. Some of them had even lost their basic accounting records. In such situation, it is extremely tough for anyone to get their accounts audited. Hence, we require a due date extension for filing returns. Should you require to cross check, here is the source of information:
a. https://en.wikipedia.org/wiki/2017_Gujarat_flood
b. https://en.wikipedia.org/wiki/2017_Northeast_India_floods
c. https://en.wikipedia.org/wiki/2017_West_Bengal_floods
d. https://en.wikipedia.org/wiki/2017_Mumbai_flood
3. India is Known to be a country or religions. Tax Payers, Tax practitioners ana Chartered Accountants, also being Social animals, belong to various ethnic groups and follow various faiths and beliefs. During the month of October, there are numerous weekly festivals like Muharram, Durga Pooja (West Bangal), Diwali, etc. Extension granted by CBDT vide notification No.F.No.225/270/2017/ITA-11 dt.31/08/2017, has resulted into overtime working by tax practitioners and Chartered Accountants during the festive season and possibly even on holidays. This already hurting religious feelings of a Large number of tax payers as well as tax practitioners (including CAs). It may be noted, that even Advocates having courtroom practice, enjoy summer and winter vacations. Thus, for a balanced, social and family life of Chartered Accountants, we hereby raise our concern over the deteriorating working conditions and earning standards of practitioners, and also demand an extension of time Limit as per Para 6 below, so as not to spoil festive weeks of practitioners during Diwali.
4. As a matter of fact to be brought to your notice, during the last few years, tax practitioners and especially Chartered Accountants, have been toiling too hard to help you achieve your fiscal targets. As can be seen from the below chart, the proportion of return filed after office hours is increasing alarmingly
| Particulars | 2015-16 | 2016-17 | 2017-18 | % Increase |
| % of Returns Filed Outside Office Hours | 53.58% | 50.78% | 54.56% | 7.44 |
**Source: www.incometaxindiaefiling.gov.in
Thus, if any tax practitioner’s office has a shift is of 8 hours, which as per above information forms less than 50% of total actual working hours, then approx 100% of time is overtime. Practitioners toil late night, to provide quality of work as per committed norms of ICAI, making their working shift of above 16 hours. And if time to eat, pray and love is deducted, the remaining time is an inhumane figure to get a sound sleep. And in return, they get meager remunerative amount. These calculations are based on a normal lot of 60 audit assesses to 1 CA.
5. It is an unwritten and unacknowledged fact, that CAs although not legally bound to deliver any particular service, but as rightly termed by Hon’ble Prime Minister of India, as Rishimuni, who strive for perfection and professionally deliver work to its results. However, considering the extreme complexities of existing laws, when read between the lines, and which have to be complied either as auditor or consultant, and work has to be taken from dumb machines, which seldom deliver service on time, the CAs have to take on the heat. One such aspiring Chartered Accountant CA Shri Tejas Manharlal Desai (Aged 42) years had gone 
into depression and later committed suicide on 13th October 2017, due to excessive GST compliance work. However, those who are still alive are dying at a slow pace within their offices. Due to such excessive work pressure and continuous sitting, members of our fraternity have become vulnerable to fatal diseases like hypertriglyceridemia, hyperlipdemia, hyper-tension, hemorrhoids, blood pressure, high sugar, Insomnia, mood swings and many more. All these are unfortunate methods of earning as well as dying. Hence, we need a sitting with you along with the officers of the Finance Ministry, with regard to simplification of compliance work. Please provide your suitable time at the earliest.
6. Sir, do you think, the tax professionals and CAs are robots, switching and routing their time and energy in multitasking to achieve your goals, completing Tax Audit on one hand as well as GST compliance on the other, amidst vicious cycles of GST late filing fees of Rs.200 per day, which were promised to be waived, by you through a press release announcing the recommendations of 22nd GST Council meeting, but the promise was never notified in writing till date. This also shows, that your own men don’t follow your orders. Is the situation of Government so pitiable, that it has to earn money out of self-created problems and a failed network. The innocent tax payers, relying upon your press release promise, have resorted to quarrel and demeaning behavior with their Chartered Accountants due to upfront collection of this hidden late fees by GSTN, without which the tax payers are not allowed to file GST returns. Hence, we require an immediate stoppage of bottlenecks created by GSTN in the form of Last minute demand of Late filing fees. Since, by the time it is paid, another late fee are charged and levied. Besides, we demand a complete refund of the erroneously charged Late fees to the Electronic Cash Ledger of respective tax payers.
7. Thus, during this historic year of paradigm change in taxation, although, which was hastily implemented along with other factors as enlisted above, we demand an extension of time limit for the following:
a. Income Tax Return Filing due date, which was extended till 31st October 2017, be further extended till 31st December 2017 to reduce/spreading over the work
b. TDS Return Filing due date, which is 31st October, be further extended till 30th November 2017.
We hope, our representation would have appraised you in light of various hardships faced by the stakeholders, and are also hopeful, that you would do justice to our grievances.
Thanks & Regards,
| For Chartered Accountants Association, Surat | |
| CA Rasesh Shah
President |
Secretary
CA Hardik Kakadiya |
Copy to: ‑
(1) Prime Minister’s Office,
152, South Block, Raisina Hills, New Delhi – 110011.
(2) Secretary (Revenue),
128/A, North Block, New Delhi – 110001
(3) Chairman, Central Board of Direct Taxes,
North Block, New Delhi – 110001
(4) GST Council Secretariat,
Tower II, 5th Floor, Jeevan Bharti Building, New Delhi – 110001
(5) Chairman, Central Board of Excise & Customs,
North Block, New Delhi – 110001
Also Read-
Request for extension of date of filing of Tax Audit Report & ITR
(Republished considering the Sensitivity of Issue)
The extension of time may be considered & no penal action may be initiated for those tax payers have have paid atleast 90% of gross tax is paid by 30th Oct. 2017. The Govt should be liberal to those who paid tax alomost to the extent of 90%.
any news for extended
Goverment/CBDT Kab Logoki Sune Ge ?
Dear all , this is waste of time conversing like this, better idea is to go in front of MEDIA, and to tell the government directly…. because even common people and business men has to understand the practical problems facing by PROFESSIONALS.. do we receive atleast a response from the govt till date?
Sir,
Yes, Govt must give the extention for filing of Tax Audit Report and Filing of Income Tax Return till 30.11.2017
HOW MANY DAYS WE WILL WAIT FOR EXTENSION
sir any other state c a association submitted the representation for date extension, how can we know that they have submitted please confirm
ALL BUSINESS MEN AND PROFESSIONALS ARE FEELING THAT THE GOVT IS HARASSING WITH TIME LIMIT AND PENATIES. TIME LIMIT FOR TAX AUDITS MUST BE EXTENDED TO GIVE RELIEF TO CA PROFESSIONALS, ACCOUNTANTS AND AS WELL AS BUSINESS MEN
ALL BUSINESS MEN AND PROFESSIONALS ARE FEELING THAT THE GOVT IS HARASSING WITH TIME LIMIT AND FINALLY. TIME LIMIT FOR TAX AUDITS MUST BE EXTENDED TO GIVE RELIEF TO CA PROFESSIONALS, ACCOUNTANTS AND AS WELL AS BUSINESS MEN,
Sir, Any chances of extension date?
what is the status of the descision of changing the financial year from march to december?.
if they do that, then at least festivals, floods and related illnesses of both men and machines will not create major issues.
voices our sentiments exactly. very well drafted.
The CA fraternity can understand the frustration that lead to the death of a CA……., but dont have too many hopes from the government, who thinks that we only keep on complaining and asking for extension.
so many farmers died… kya hua?
Tax Consultant,
The issue of the need for extention is not limited to few states. In this particular year, almost all parts of the country of affected by natural calamities in one form or the other, though the intensity may vary. Then the Ghost of GST, ICTC etc. have added further fuel. In the field of GST one has lost count of the number of notifications and extentions. There is a big chaos among the audit community and the general public.In spite of this, majority of the masses are striving hard to keep up with all the compliances. The technical problems like survor down etc. apart, it is to be noticed that no one is not yet frustrated, because everyone is looking for light at the end of the tunnel. The only fact of almost every statute being changed/amended at one stretch has been the root cause. Quality and honest compliance and human health should take more priority in this year of a sort revolutionary time.
Hence, request and need for extention is tenable. The powers that be, should act voluntarily before the positive response of the public towards historic shift-overs gets completely diluted.
Request for extension of TAR & ITR is given by all states of CA Association which shows the Unity & seriousness of workload & responsibility given to all CA feternity. It is surprised that on diwali festival Govt. not announced the extension of GST-3B date.Tax audit date must be extended due to heavy load of GST compliances. Govt. Should immediately issue notification regarding date extension.
Yes, Govt must give the extention for filing of Tax Audit Report and Filing of Income Tax Return till 30.11.2017
Its really important for us.. The work load is so huge that we could not even enjoy our festivals.. Even then the work is not going to get done before due date.. Still 40% of our work is still pending resulting in compromising the audit quality.
Any chances of extension?
Sir Date extended kab hogi
our humble request for other states association to come forward and submit the request to cbtd for extension of time and the value of C A. Please come forward and submit the representation as surat and rajasthan done, we really appreciate their issue and they know the difficulties we are facing for tax audit, come forward for the sake of our brother who given his life.
tax audit limit has to extend soon as possible
even representation has been mail to all ca and tax consultant association are they not responding?
GST Return filling due dates are required to be increased permanently and Tax audit date must be extended due to heavy load of GST & Income and TDS compliances and Diwali festival. Being a sensitive Govt. , Should immediately issue notification regarding date extension. Govt. must understand the level of stress and difficulties faced by the people of our country.
Why all other states CA ASSOCIATIONS are not submitting their request for extention of time, If not done, How the GOVERNMENT WILL BOTHER? They think that this demand is from only few states, and others are comfortable.. is it not so ? ..
Good representation made before the ministry!. Hope they understand the genuinity of the problems being faced by CA fraternity and business people for the kind of amendments recently made by the govt. People are forced to pay fine even if the delay is caused because of technical glitches in GSTN whicn is never a fault of bonafide taxpayers. Will the govt. ever think of compensating the business houses for the problems being faced by them due to unthoughtful implementation of GST and ineffective GST portal?
Every words are perfect,,, We all are with Chartered Accountants Association, Surat,
From,
Bangalore
Wheather this conversations reaching to all CA ASSOCIATION OF INDIA.. DO THEY KNOW ABOUT surat and Maharashtra etc. CA ASSOCATIONS are requesting for extension of time… wheather other state CA ASSOCIATIONS KNOW ABOUT THIS, OR THEY DONT WANT THIS, OR THEY DONT TO JOIN US ?
Mr. Jaitly must be open his eyes on this issue he is just lawyer not A CA and can not understand our problem at his level so PM Must be inter fare and to xtend the time upto demanded period Thanks to Chartered Accountants Association,Surat
who have raised voice for extending due date of Tax Audit.It is very Difficult to handle Tax Audit . CA Institute must be put this demand on the table of FM
Dear All, What we conversing here is a waste of time, Anybody seen todays news paper? The Department reminding the public to file 44AB return before 31th Oct Itself…. That means they have not given a penny value respect to the requests of all CA and ASSOCIATES… So, think of dropping the issue , or to do something else. OR keep quite. because this is INDIA …
For quality tax audit, we have need some time.
date should be immediately extended for the sake of quality audit
AUDITOR SEKAR your observation is practical, but lets hope that does not happen.
BABU we mailed our representation to all the “To and CC” concerned parties, besides, we also submitted a PDF submission on pmindia.gov.in which is lodged in cpgrams, so by this time he may have got the message.
SUNIL KUMAR and Radheshyam, instead of strike, lets not submit the Audits, let the genuine or not so genuine late clients feel the heat, they should also represent through their respective trade associations. Finally Audit and GST are both babies of the Trade & Industry. We are merely “Yashoda Ma”.
Request you all to please share this content further and again make it viral. I urge, other associations too join us.
What ICAI is doing ???
Are they not bothered about their members???
Nor aware of the situation of Accunting Profession in India ??? Why every year state Associations had to make representations on deaf ears ???
Dear sir
Gst work is very difficulty gst r 3 return time up to 10th Nov.17 tax audit due date31.10.2017.gst 3b sep due 20.10.2017.gst r 2 due 31.10.2017.we have to work which is first.late filling gst rs.200/ per day.Auditors having many problem to file gst.internet working as slow. we request to central government further extended for 44ab case up to
Dec.2017.Thanking you
dec.31.2017.t
Thanks to CAAS representing the exact issues to the govt. We request the govt to extend the due date considering the facts.
sir bhaut bekar depawli man rhi he mere depawli to andhkarmay ho rhai he tenson bad rha he agar dt nhi badi to nokri pesa sab barbad ho jayga
sir pl. new dt. in tax audit 30.11.2017
sir why other states not showing interest in this issue of extension. thank you surat and rajasthan shareing our difficulties thank you very much
sir.date extend hona bahut jarurui he..varana accountants mar jaenege..log bahut preshan hein..iss diwali jitni ghatiya diwali kabhi nahi ayi..state governments ne apne employees or contractors ko salary or fee paid nahi ki..kiu k unho ne keh diya k gst k karan centre ne paisa nahi diya..post matric scholarship for sc/obc students ko apply karne wale colleges ko state govenments ne students ki fee nahi di..to bahut se college management ne loan lekar one month ki salary di..sir..gst k karan amm log pehle hi preshan hein..tax reforms kashatdayik ho sakte hein..lekin ese nahi..ke logo ki jaan hi le lein..note bandi me hum pehle hi bahut hi life loss kar chuke hein..kirpya ab or na kuch ho sambhaleye..diwali barbad ho gai..ab jindgi na barbad ho..date badaeye..
DON’T WORRY Sir,
As usual our Government will extend the Date of filing of return up to 6th, November. (one week) saying : “Upon many representations received from auditors and in the interest of public government is extending the due date up to 6th of November”. (Since 4th, and 5th becomes a Holiday, Nobody will cooperate in the office), On 6th November INCOME TAX website will not work/ or very slow. Inspite of that we will file the returns by 12th hour.
On 7th November Our Hon’ble FINANCE MINISTER will anounce “with the co-operation of OUR BUSINESSMAN” Government received all the tax audit returns.
This is our fate, don’t worry. HAPPY FILING, HAPPY PENALTY,
MODI ki Jindabad.
Now,today no need to extend because all our Diwali has gone, all our staff is working in this most importanat festival, when they will give extension after 25th…?????
Tomorrow Diwali will be over…Whats the use of extension.Only our profession is under tremendous pressure & tension.
dear sir
this is to state that 90% of taxes already paid through advance taxes already revenue gone to goverment only paper returns is there as you know because of GST so many confusion is there now 20th clients is coming now again to file gst no time since from july for tax audit work still pending please humble request to extend the date till december or atleast till 30 november it is very helpful for us so that atleast we can relax with children for a day or in their school holidays. Our brother made suicide because of work load of gst please we too are facing the same problem please extend the date your gift for this Diwali do the needful extend the date. Bombay association please file the recommendations for extenstion
it is a must to extention
Good decision by CA association surat
Why Mr Modi is kept his eyes closed like congress. What is the differences if Government is not concerned with the problem of the citizen.
It is simply rigidness of the Government nothing else. if Government extend the date for another a month they will loose nothing.
We need the extension any how majority of Tax Audits are pending due to Gst Implementation issues we are facing lots of problem
First the filing of GST returns should by away from any difficulties.It should have the provision of alteration after submission but before filing.The cash ledger must be common.So that any one paid wrongly in other area will not create any problem.If it is a common cash ledger it could be used for any one which need the payment.And then there should not be any fine or late fee up to March 2018 or until the problems solved.Daily we have to work for GST…GST…GST.It can be avoided only the Govt and Tax officials put their sincere effort to avoid this kind of problems.
Dear All, what all we commenting here, will this reach to the GOVERNMENT or atleast to the OTHER \ALL STATE CA ASSOCIATION people? And how to know the latest steps taken by government about this request submitted by surat and Gujarat states etc..?
dear sir maharastra, karnataka, delhi, kolkata request for these association to come forward for date extension.
Tax audit date must be extended due to heavy load of GST compliances. Govt. Should immediately issue notification regarding date extension.
The Tax audit to be extended upto december since the major time spent is out compliance of the GST work and another major issue is with the Late fee for GST this late fee me defered till marh 2018 so the genral pubilc may get used to with the GST returns
Government should understand that we are not machine or Robot. How is it possible for a Tax Professional to complete these works within stipulated time.The extension of Date of Audited Return and TDS Return is urgently required.