TaxTMI 
TaxTMI 
TaxTMI 
Why MCTC Has Requested an Extension of ITR & Audit Report Deadlines for AY 2025-26! Every tax season brings with it a sense of urgency. Balance sheets are finalized, returns are verified, and professionals work long hours to ensure that their clients meet deadlines without error. Yet, behind the scenes, the landscape is not always as smooth as it appears. Technical hiccups, procedural changes, and systemic delays often place professionals and taxpayers under immense stress. This year, the challenges have been unusually pronounced. While the Government deserves appreciation for its proactive decision to extend the due date for non-audit cases from 31st July to 15th September, the ground reality continues to reflect enormous pressure on compliance. Recognising this, The Malad Chamber of Tax Consultants (MCTC) has made a formal representation to the Hon’ble Finance Minister, Smt. Nirmala Sitharaman, and the Hon’ble Chairman, CBDT, Shri Ravi Agrawal, seeking further extension of deadlines for filing Income Tax Returns and Audit Reports for AY 2025-26. The Practical Challenges on the Ground
1. Delayed Release of 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. Advertisement ITR-5—critical for partnership firms, LLPs, AOPs, and trusts—was released as late as 8th August. ITR-6 and ITR-7—used by companies and trusts—are still awaited. Even the forms that were released earlier (ITR-2, ITR-3) underwent further updates at the end of July, forcing professionals to redo their work and wasting precious days.
2. Technical Glitches & Errors Despite significant upgrades to the Income Tax portal in recent years, many professionals continue to report persistent system errors: Errors in capital gains schedules within ITR-2. Difficulty in uploading audit reports without rejections. Minor mismatches triggering automated demand notices, which create unnecessary anxiety.
3. AIS/TIS Data Discrepancies The Annual Information Statement (AIS) and Tax Information Summary (TIS) were designed to help taxpayers with better reporting. But multiple instances of mismatches between AIS and TIS have been noted. In many cases, the data is not downloadable at all. This forces professionals into manual reconciliations that consume time and increase the risk of error.
4. New ICAI Reporting Format The Institute of Chartered Accountants of India (ICAI) introduced a revised vertical format of financial statements for non-corporate entities from FY 2024-25. While this is a welcome step towards standardisation, adapting to it requires additional time for redesigning financials, educating staff, and ensuring reconciliations. The timing of its rollout, coinciding with return filing deadlines, has made compliance more demanding.
5. Festive Season Constraints September to November is also a period of India’s most celebrated festivals—Ganesh Chaturthi, Onam, Navratri, Durga Puja, Dussehra, and Diwali. Offices close, staff travel, and businesses focus on seasonal activity. For tax professionals, this means fewer effective working days precisely when deadlines are looming large. MCTC’s Suggested Timelines Taking into account these genuine hardships, MCTC has humbly appealed for revised deadlines as follows: Compliance Category Current Due Date Proposed Due Date ITRs (Non-Audit Cases) 15 Sep 2025 30 Oct 2025 Audit Reports (Form 3CD)30 Sep 2025 30 Nov 2025 Audit Reports (u/s 92E) 31 Oct 2025 31 Dec 2025 ITRs (Audit Cases) 31 Oct 2025 31 Dec 2025 ITRs (u/s 92E) 30 Nov 2025 31 Jan 2026 Belated Returns 31 Dec 2025 28 Feb 2026 Why an Extension is Not a Delay, but a Relief Granting more time is not about postponing compliance—it is about making compliance meaningful. When deadlines are compressed: Professionals are forced into rushed filings, which increase the risk of mistakes. Honest taxpayers are penalised for systemic issues beyond their control. The spirit of voluntary compliance is dampened when anxiety replaces certainty. An extension will: Allow professionals to file returns with accuracy and confidence. Reduce avoidable litigation and rectification cases. Reflect the Government’s empathetic and collaborative approach to compliance. Ultimately strengthen the trust between taxpayers and administration. A Collective Hope The Malad Chamber of Tax Consultants has always stood for constructive dialogue with the Government. As representatives of over 1,350 professionals who serve thousands of taxpayers, MCTC’s appeal is not just about dates on a calendar—it is about ensuring that compliance is effective, accurate, and stress-free for all stakeholders. We sincerely hope that the Finance Ministry and CBDT will consider this representation with sympathy and pragmatism. An extension granted today will not only bring relief but will also reaffirm the belief that the tax administration of our country is sensitive to ground realities. Issued on behalf of The Malad Chamber of Tax Consultants (MCTC) Adv. Rinav Khakhar – President CA Atul Ruparelia – Chairman, Law & Representation Committee
The Malad Chamber of Tax Consultants Date: August 20, 2025
To,
Smt. Nirmala Sitharaman, Hon’ble Finance Minister of India, North Block, New Delhi – 110 001. Shri Ravi Agarwal, Hon’ble Chairman, Central Board of Direct Taxes, North Block, Delhi – 110 001.
Sub.: Request for Extension of Due Dates for Filing of Income Tax Returns and Audit Reports for Asst. Year 2025-26 Respected
Madam/Sir,
The Malad Chamber of Tax Consultants (“MCTC”) is an Association having around 1350 members from diverse professional practitioners like Chartered Accountants, Advocates, Company Secretaries, Cost Accounts and Tax Practitioners. The Chamber was established in the year 1978 with the main objective of spreading knowledge amongst its members in particular and public at large in general. It is registered under the Societies Registration Act, 1860 and the Bombay Public Trust Act, 1950. MCTC is regularly conducting Study Circle Meetings, Seminars, Workshops, Refresher Courses etc. on the subject of Direct and Indirect Taxes. We extend our heartfelt appreciation to the esteemed office and Government for their outstanding efforts in developing and maintaining the updated Income Tax portal, showcasing a strong commitment to digital governance. Furthermore, we express sincere gratitude to the Finance Ministry and Central Board of Direct Taxes for their proactive stance in acknowledging the necessity for an extension in filing the Return of Income for non-audit assesses. Recognizing the genuine challenges posed by statutory changes in the Income-tax Act and corresponding updates to the Income-tax Return Forms, the Board has prudently extended the due date from July 31, 2025, to September 15, 2025. This timely extension has provided much-needed relief, enabling taxpayers to comply with the updated regulations without undue haste. We are writing to bring to your attention the practical challenges faced by taxpayers, Chartered Accountants, and other stakeholders in filing Income Tax Returns and Tax Audit Reports for the Financial Year 2024-25 (Assessment Year 2025-26). Although the recent extension of the due date has provided some relief, we believe that further consideration is warranted to address the complexities and difficulties encountered. In light of the genuine challenges outlined below, we respectfully request an extension of the due dates for filing Income Tax Returns for both assesses subject to audit and those not subject to audit and Tax Audit Reports. The specific difficulties are as follows:
1. Marginal Time between ITR Utility Release Date and Due Date: The ITR Utilities, which are usually available by April of every year, have been delayed and staggered this time. The various release dates are as under: Income Tax Return / Form Date of Release of Utility ITR – 1 30-May-2025 ITR – 2 11-Jul-2025 ITR – 3 11-Jul-2025 ITR – 4 30-May-2025 ITR-5 08-Aug-2025 ITR-6 Not yet released ITR – 7 Not yet released Form 3CA – 3CD 29-Jul-2025 Form 3CB – 3CD 29-Jul-2025
2. Update of Utilities after a Delayed Release: The ITR Utilities, which were released late, have been further updated. The various updation dates are as under: Income Tax Return /Form Date of Original Release of Utility Date of Latest Update ITR – 1 30-May-2025 30-Jul-2025 ITR – 2 11-Jul-2025 30-Jul-2025 ITR – 3 11-Jul-2025 30-Jul-2025 ITR – 4 30-May-2025 30-Jul-2025
3. Limited Time for ITR - 5: The ITR-5 utility, applicable to a wide range of taxpayers including Partnership Firms, Limited Liability Partnerships (LLPs), Association of Persons (AOPs), Body of Individuals (BOIs), Estates, Trusts, and Artificial Juridical Persons (AJPs), was released belatedly on August 8, 2025. Key Challenges: – Limited Timeframe: Taxpayers have approximately 38 days to prepare and file their returns, which may not be sufficient given the complexity of the task. – Complexity of ITR Forms: The new ITR forms for AY 2025-26 introduce more detailed disclosure requirements, which may require additional time and effort to complete accurately. – Potential for Errors: The rush to meet the deadline may lead to errors in filing, which can result in penalties and interest on tax dues.
4. System Errors while uploading ITRs and Audit Reports: 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. Key Challenges: – Insufficient Time: Taxpayers have limited time to compile financial data, ensure accuracy of computations and file returns. – Errors in ITR-2 Utility: Issues with intra-head adjustment of short-term and long-term capital losses may lead to incorrect tax computation. – Manual Reconciliation: Professionals are investing considerable time in manual reconciliation to avoid potential errors. – Automated Demand Notices: Minor errors may trigger automated demand notices, adding to taxpayer anxiety. – Penalties and Interest: Inaccurate filings may result in penalties and interest on tax dues.
5. Inconsistencies in Form 26AS, AIS and TIS: Discrepancies and technical issues have been noted with the Annual Information Statement (AIS) and Tax Information Summary (TIS) data. Key Challenges: – Data Discrepancies: Differences have been observed between AIS and TIS data for the same Permanent Account Number (PAN) when downloaded simultaneously. – Data Unavailability: Multiple instances have been reported where AIS and TIS data could not be downloaded despite repeated attempts. These issues may cause inconvenience and delays in tax compliance.
6. Other Issues: Festivals: India’s diverse festivals, such as Ganesh Chaturthi, Onam, Eid-e-Milad, 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. Consequently, taxpayers and professionals face challenges in completing the timely preparation, review, and filing of Income Tax Returns and Audit Reports. 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. Appeal for Extension: We respectfully request that you consider the challenges and complexities outlined above and grant an extension of the due date for filing Income Tax Returns and Tax Audit Reports for both audit and non-audit assesses. This would provide necessary relief and enable taxpayers and professionals to comply with the statutory requirements efficiently. We humbly suggest as under: Particulars Due Date as of now Proposed Due Date ITRs (Non-Audit Cases) 15-Sep-2025 30-Oct-2025 Audit Report 30-Sep-2025 30-Nov-2025 Audit report (u/s 92E) 31-Oct-2025 31-Dec-2025 ITRs (Audit Cases) 31-Oct-2025 31-Dec-2025 ITRs (u/s 92E) 30-Nov-2025 31-Jan-2026 Belated Returns 31-Dec-2025 28-Feb-2026 We sincerely hope that your office will sympathetically consider our representation and take appropriate action, facilitating a smoother tax compliance process for all stakeholders.
Yours Truly,
For The Malad Chamber of Tax Consultants
sd/- Adv. Rinav Khakhar President
sd/- CA Atul Ruparelia Chairman Law and Representation Committee