Chartered Accountants body Seeks Uniform Relief for Taxpayers Filing Form 3CEB u/s 92E of Income Tax Act [Read Circular]

The Association has requested the CBDT to extend the same filing relief to taxpayers covered under Section 92E of the Income Tax Act for the Assessment Year 2025-26.

In its representation to CBDT Chairman Shri Ravi Agarwal, the KSCAA appreciated the government’s decision to extend the due dates for filing income tax returns and audit reports for assessees whose accounts are required to be audited under Section 44AB.

The Board had extended the date for filing tax audit reports to 10 November 2025 and the date for filing income tax returns to 10 December 2025.

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However, the Association pointed out that this extension was granted only to assessees referred to in clause (a) of Explanation 2 to Section 139(1). It did not cover those under clause (aa), who are required to furnish an accountant’s report under Section 92E for international or specified domestic transactions.

According to KSCAA, this creates an uneven situation. Companies that are subject to transfer pricing regulations and face more complex compliance obligations are still required to file their income tax returns by 30 November 2025.

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Other audit cases with fewer reporting requirements can file their returns by 10 December 2025. The Association said this is unfair and inconsistent with the government’s usual practice of granting uniform extensions for all audit-related categories.

KSCAA has urged the CBDT to examine this issue and issue a clarification or corrigendum to ensure parity and fairness among taxpayers. It stated that extending the due dates for Section 92E assessees will align with the CBDT’s long-standing approach of providing equitable relief and facilitating compliance.

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