Tax Audit Deadline Not Extended for These Taxpayers; Karnataka CA Body Highlights Anomalies in CBDT’s Due Date Extension Circular
Issue: The Central Board of Direct Taxes (CBDT) extended the due dates for the Tax Audit Report (TAR) and Income Tax Return (ITR) for most audit cases, but its official circular failed to grant similar extensions to assessees who are also required to furnish reports for international or specified domestic transactions under Section 92E (Transfer Pricing).
Facts:
- The CBDT issued Circular No. 15/2025 (dated October 29, 2025), extending the due date for the TAR to November 10, 2025, and the ITR deadline (for audit cases) to December 10, 2025.
- The Karnataka State Chartered Accountants Association (KSCAA) formally wrote to the CBDT, pointing out the omission of assessees required to furnish the accountant’s report under Section 92E (Form 3CEB).
- The standard due date for ITR filing for Section 92E assessees is November 30 (one month earlier than the general audit deadline).
Decision:
The CBDT’s circular created an unintended anomaly by being silent on the extension for Section 92E assessees, effectively mandating an earlier compliance deadline for taxpayers who face a higher compliance burden (Transfer Pricing documentation).
Key TakeDowns:
- Compliance Inconsistency: The omission is inconsistent with the principle of fairness and the Board’s past practice of providing uniform relief across all audit-related categories, forcing taxpayers with the greatest statutory responsibilities to adhere to an earlier deadline.
- Higher Burden: Assessees under Section 92E face a high compliance burden due to extensive transfer pricing documentation and reporting requirements.
- Relief Sought: The KSCAA requested that the CBDT immediately extend similar relief to assessees covered under Section 92E to align their deadlines with the December 10, 2025 ITR filing deadline granted to other audit cases.
Source :- Economic Times