CAs seek Transfer Pricing Audit, ITR Deadline Extension after Audit ITR gets Extended by CBDT

The Central Board of Direct Taxes (CBDT) on Wednesday announced an extension of key filing deadlines for the Assessment Year (AY) 2025–26, offering much-needed relief to taxpayers and professionals amid persistent compliance pressure.

As per the latest notification, the due date for furnishing audit reports has been extended to November 10, 2025, while the deadline for filing Income Tax Returns (ITRs) for entities subject to audit has been pushed to December 10, 2025.

While the move has been widely welcomed by taxpayers and audit professionals, tax experts have pointed out a crucial omission: the absence of a corresponding extension for Transfer Pricing (TP) audit reports and Transfer Pricing returns.

According to CA Jainik Vakil, Chairman of the Direct Tax Committee of the Gujarat Chamber of Commerce and Industry (GCCI), the CBDT’s latest circular has not addressed the statutory timeline applicable to Transfer Pricing cases. Vakil explained that as per Section 92E of the Income Tax Act, 1961, the due date for furnishing the TP audit report (Form 3CEB) is one month before the due date of filing the Transfer Pricing Income Tax Return (TP-ITR).

He further clarified that under Section 139(1), the due date for filing the TP-ITR is November 30, 2025. Therefore, in the absence of a specific extension, the due date for submitting the TP audit report automatically remains October 31, 2025. The CBDT has extended the due date of filing ITR to December 10 and of furnishing audit reports to November 10. However, the due date for filing the TP audit report (Form 3CEB) has been missed out, he said to TOI, urging the Board to issue a separate notification to extend the timelines for TP filings as well.

Vakil laid emphasis on Transfer Pricing compliance being a highly technical and data-intensive exercise, often involving complex benchmarking studies and extensive documentation that Section 92E specifically governs TP audit timelines, the authorities must issue a separate notification extending both the TP audit report and the corresponding ITR filing deadlines.

He added that a significant proportion of audited entities fall under the Transfer Pricing category saying that Nearly 15% of all audit reports pertain to Transfer Pricing cases, representing a substantial compliance workload for both taxpayers and auditors.

Industry Reaction and Expectations

Tax professionals across the country have echoed similar concerns, noting that many businesses engaged in cross-border transactions require additional time to finalize their TP documentation and ensure compliance with global and domestic pricing norms. They argue that extending only the general audit and ITR deadlines without addressing TP-related filings creates an inadvertent compliance gap and potential legal ambiguity.

Experts have urged the CBDT to issue a clarificatory circular to bring uniformity in due dates for all categories of taxpayers, including those covered under Transfer Pricing regulations. Such an extension, they say, would ensure consistency, reduce litigation risk, and help ease the compliance burden on multinational and large domestic enterprises.

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