Representation to CBDT for Extension of AY 2026-27 Tax Audit and Audit-Case Return Due Dates
Bhartiya Vaishya Global Foundation has addressed a detailed representation dated 22 September 2026 to the Chairman, Central Board of Direct Taxes, seeking relaxation in the statutory timelines for tax audits and related return filings for Assessment Year (AY) 2026-27. The organisation has requested an extension of the specified date under Section 44AB for furnishing Tax Audit Reports from 30 September 2026 to 31 October 2026, and a corresponding shift in the due date for filing returns in audit cases from 31 October 2026 to **30 November 2026`.
The Foundation represents a wide spectrum of the Vaishya business community including traders, manufacturers, MSMEs, proprietary businesses, partnership firms, family-run companies, and associated professionals. A substantial portion of assessees falling within the ambit of Section 44AB are stated to be part of this constituency.
In its representation, the Foundation aligns itself with earlier requests submitted by other professional and trade bodies, and then independently sets out a comprehensive set of grounds to justify the sought extensions.
Background and Core Request
The primary plea in the representation is twofold:
- To shift the statutory “specified date” for tax audit reports under
Section 44ABfor AY 2026-27 from 30 September 2026 to 31 October 2026. - To similarly extend the due date for filing income-tax returns in audit cases (including company returns in
ITR-6) from 31 October 2026 to 30 November 2026, along with consequential adjustment for transfer-pricing compliance in Form3CEB.
The Foundation emphasises that its representation is made in continuation of, and in support of, previous memoranda dated 6 September 2026, 8 September 2026 and 16 September 2026 submitted by different associations, but the present communication independently spells out the special circumstances for AY 2026-27.
Legal Framework and Assumed Preconditions for the Timelines
Linkage between audit date and return due date
The representation notes that the legislative design of Section 44AB is to ensure that the audit of accounts is completed well before the income-tax return is filed, so that returns are based on reviewed and reconciled financial information. The statute essentially links the “specified date” for audit reports to a date one month prior to the due date for filing returns in audit cases.
According to the Foundation, this structure presupposes certain basic conditions:
- The applicable financial statement format for the relevant entities should be known and stable sufficiently early.
- The income-tax return forms, their schemas and related utilities should be notified in good time, and once notified should remain stable without frequent amendments.
- Professionals should have a reasonable and uninterrupted effective working window between the close of non-audit return work and the tax audit deadlines.
The representation asserts that for AY 2026-27, all three of these assumptions have failed, resulting in a situation where the scheduled due dates no longer support the original legislative intent of a careful, well-reconciled audit preceding the filing of returns.
Power of CBDT to extend time limits
The Foundation highlights that under Section 119 of the Income Tax Act 1961, the CBDT has the authority to relax timelines in appropriate circumstances and to issue orders for proper administration of the Act. It references that in the preceding year, the Board had already exercised this power to extend the tax audit due date from 30 September 2025 to **31 October 2025`. On this basis, it submits that the present, more complex difficulties justify a similar or stronger intervention for the current year.