Impact of extended deadlines for compliances under the Income-tax Act

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  • Last Updated on 13 September, 2021

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In view of the COVID-19 pandemic, the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (TLA Act, 2020) has extended various due dates of compliances. The due dates so extended by the TLA Act, 2020 have been extended again on multiple occasions by the CBDT1.

Income Tax Compliances Due Dates

The CBDT has again extended the due dates for certain compliances2. The impact of new circular on various time barring dates and certain compliance of Income-tax Act is as under:

Section Particulars Original Due Date Due date extended by the TLA 2020 read with previous notifications New Due dates
Section 139(1) Return of income for the assessment year 2021-22 for all assessee other than

  1. corporate-assessee;
  2. non-corporate assessee (whose books of account are required to be audited);
  3. partner of a firm whose accounts are required to be audited or the spouse of such partner if the provisions of section 5A apply; or
  4. an assessee who is required to furnish a report under section 92E.
 31-07-2021 30-09-2021 (see notes) 31-12-2021 (see notes)
Section 139(1) Furnishing of return of income for the assessment year 2021-22 if the assessee (not having any international or specified domestic transaction) is:

  1. corporate-assessee;
  2. non-corporate assessee (whose books of account are required to be audited); or
  3. partner of a firm whose accounts are required to be audited or the spouse of such partner if the provisions of section 5A apply.
 31-10-2021 30-11-2021 (see notes) 15-02-2022 (see notes)
Section 139(1) Furnishing of return of income for the assessment year 2021-22 in the case of an assessee if it is required to submit a report under section 92E pertaining to the international or specified domestic transaction(s) 30-11-2021 31-12-2021 (see notes) 28-02-2022 (see notes)
Section 44AB Due date for filing of audit report under section 44AB for the assessment year 2021-22 in the case of a corporate-assessee or non-corporate assessee (who is required to submit his/its return of income on October 31, 2021) 30-09-2021 31-10-2021 15-01-2022
Section 44AB Furnishing of report from an accountant for the assessment year 2021-22 by an assessee entering in to international or specified domestic transactions under Section 92E 31-10-2021 30-11-2021 31-01-2022
Section 139(4)/(5) Furnishing of belated or revised return of income for the Assessment Year 2021-22 30-11-2021 31-01-2022 31-03-2022
Sections 10(23C), 12A, 35, 80G Filing of application in Form 10A for registration/provisional registration/intimation/approval/provisional approval of Trust, institutions or Research Associations, etc. 30-06-2020 31-08-2021 31-03-2022
Sections 10(23C), 12A, 80G Filing of application in Form 10AB for conversion of provisional registration into regular registration or renewal of registration/approval after five year of registration/approval of Trust, institution, etc. Date of filing falls on or before 28-02-2022 – 31-03-2022
Rule 37BB Quarterly Statement in respect of foreign remittances (to be furnished by authorized dealers) in Form No. 15CC for:
Quarter ending June, 2021 15-07-2021 31-08-2021 30-11-2021
Quarter ending September, 2021 15-10-2021 – 31-12-2021
Section 167 of the Finance Act 2016 Furnishing of Equalisation Levy statement for the Financial Year 2020-21 30-06-2021 31-08-2021 31-12-2021
Direct Tax Vivad se Vishwas Act, 2020 Payment of tax without additional charge – 31-08-2021 30-09-20213
Direct Tax Vivad se Vishwas Act, 2020 Payment of tax with additional charge – 31-10-2021  31-10-20214
Rule 114B/114C Upload the declarations received from recipients in Form No. 15G/15H during
Quarter ending June, 2021 15-07-2021 31-08-2021 30-11-2021
Quarter ending September, 2021 15-10-2021 – 31-12-2021
Section 10(23FE) read with Rule 2DB Intimation in Form 10BBB to be made by a pension fund in respect of each investment made in India for
Quarter ending June, 2021 31-07-2021 30-09-2021 30-11-2021
Quarter ending September, 2021 31-10-2021 – 31-12-2021
10(23FE) Intimation in Form II by Sovereign Wealth Fund in respect of investment made in India for
Quarter ending June, 2021 31-07-2021 30-09-2021 30-11-2021
Quarter ending September, 2021 31-10-2021 – 31-12-2021
Section 286(1) read with Rule 10DB Intimation by a constituent entity, resident in India, of an international group, the parent entity of which is not resident in India (Form 3CEAC) Required to be furnished on or before 30-11-2021 – 30-12-2021
Section 286(4) read with Rule 10DB Report by a parent entity or an alternative reporting entity or any other constituent entity, resident in India (in Form no. 3CEAD) Required to be furnished on or before 30-11-2021 – 31-12-2021
Section 286(4) read with Rule 10DB Intimation on behalf of an international group (in Form no. 3CEAE) Required to be furnished on or before 30-11-2021 – 31-12-2021
The recent circulars don’t further extend the following due dates (which were extended previously). Thus the previously extended due date shall be the final due date for all the compliances mentioned below:
Section 54 to 54GB Making Investments or completing construction/purchase for claiming deduction from capital gains (The extension has been given in those cases where the due date falls between 01-04-2021 to 29-09-2021). Falling between 01-04-2021 to 29-09-2021 30-09-2021 30-09-2021
Section 139AA Linking of Aadhaar number and PAN 31-03-2020 30-09-2021 30-09-2021
Section 139AAread with Rule 114AAA PAN to be treated as inoperative due to non-linking it with Aadhaar number 31-03-2020 31-03-2020Error! Bookmark not defined. 31-03-2020Error! Bookmark not defined.
Section 153/153B Passing of order for assessment or reassessment by AO
Cases where on account of various extension notifications, the due date is getting expired on 31-03-2021. – 30-09-2021 30-09-2021
Cases where due date is getting expired on 31-03-2021 without giving effect of any extension notification. 31-03-2021 30-09-2021 30-09-2021
Section 168 of the Finance Act 2016 Sending intimation of processing of Equalisation Levy (The extension has been given in those cases where the due date falls between 20-03-2020 to 31-03-2021) – 30-09-2021 30-09-2021
Chapter XXI of the Income-tax Act Imposition of penalty (The extension has been given in those cases where the due date falls between specified period) – 30-09-2021 (due date falls between 20-03-2020 to 29-09-2021) 30-09-2021 (due date falls between 20-03-2020 to 29-09-2021)
Section 115UBread with Rule 12CB Statement of income paid or credited by investment fund to be furnished to PCIT/CIT in Form 64D for the previous year 2020-21 15-06-2021 15-09-2021 15-09-2021
Section 115UB read with Rule 12CB The Statement of Income paid or credited by an investment fund to its unit holder in Form No. 64C for the Previous Year 2020-21 30-06-2021 30-09-2021 30-09-2021
Benami Act Issue of notice or passing of any order under Benami Act (The extension has been given in those cases where the due date falls between 20-03-2020 to 30-06-2021) – 30-09-2021 30-09-2021

Notes:

    1. Though the due date for filing of Income-tax Return for the Assessment Year 2021-22 has been extended, but no relief shall be provided from the interest chargeable under section 234A if the tax liability exceeds Rs. 1 lakh. Thus, if self-assessment tax liability of a taxpayer exceeds Rs. 1 lakh, he would be liable to pay interest under section 234A from the expiry of original due dates.
    2. A resident senior citizen who does not have any income from business or profession is not required to pay advance tax and he can pay the entire tax by way of self-assessment tax. For computing the limit of Rs. 1 lakh (as specified above), the self-assessment tax paid by a senior citizen on or before 31-07-2021 shall be deemed to be the advance tax. Thus, same shall be reduced while computing the tax liability of Rs. 1 lakh.

■■

  1. Notification S.O. 1703(E), dated 27-04-2021, Circular no. 08/2021, dated 30-04-2021, Circular no. 9/2021, dated 20-05-2021, Notification Nos. 74 & 75/2021, Circular no. 12/2021, dated 25-06-2021 and Circular no. 15/2021, dated 03-08-2021
  2. Circular no. 16/2021, dated 29-08-2021 and Circular no. 17/2021, dated 09-09-2021
  3. Press Release, dated 29-09-2021
  4. Last date for making payment (with additional charges) hasn’t been extended. It would be same as notified earlier, i.e., 31-10-2021.

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