ICAI submits Representation to Finance Ministry about Tax Audit Report Due Date, Other Income Tax Related Concerns [View Representation Here]

The Institute of Chartered Accountants of India (ICAI) has written to the Central Board of Direct Taxes (CBDT) addressing concerns over income tax compliance timelines for Assessment Year 2025-26.

The representation was addressed to CBDT Chairman Shri Ravi Agrawal, seeking parity in due dates for return filing, tax audit reports under section 44AB of the Income Tax Act, 1961 and renewal requirements for charitable trusts.

ICAI pointed out that during the previous year, the income tax return (ITR) forms were released well in advance, ITR 1 to 6 were notified by January 2024, while ITR 7 was notified by March 2024. The utilities for filing were enabled by April to June 2024, giving taxpayers adequate time for compliance.

For the current year, however, the forms were notified late and in phases: ITR 1 and 4 became available only in May 2025, ITR 2 and 3 in July, and ITR 5, 6, and 7 in August 2025. Further, the tax audit utility (Form 3CA-3CD/3CB-3CD) was released on 18 July 2025, compared with 1 April in the previous year.

While CBDT extended the ITR filing deadline for non-audit cases from 31 July to 15 September 2025, no corresponding relief was given to taxpayers whose accounts are subject to audit and who must file returns by 31 October 2025. ICAI stressed that the “specified date” for furnishing tax audit reports under section 44AB continues to be 30 September, creating a compressed compliance window.

According to ICAI, the Income-tax Act intentionally prescribes distinct due dates to ensure at least two months between return filing and audit deadlines. By shifting the initial ITR due date from 31 July to 15 September without adjusting other dates, this balance has been disturbed. ICAI has therefore requested that the “specified date” under section 44AB and the 31 October return filing deadline be correspondingly shifted to maintain statutory intervals and reduce hardship.

The representation also addresses renewal requirements for small charitable trusts and institutions registered under sections 12AB and 10(23C). Many registrations granted from 1 April 2021 are due to expire on 31 March 2026, which requires renewal applications in Form 10AB to be filed by 30 September 2025. ICAI suggested that in cases where conditions such as income thresholds are met, the validity should be deemed auto-renewed for another five years, avoiding unnecessary compliance. Similar relief was sought for trusts registered under section 80G of the Income Tax Act.

ICAI put forth the argument that parity across deadlines will reinforce the statutory intent and ensure fair treatment of taxpayers and professionals alike.

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