Request to extend tax-audit and audit-report deadlines for AY 2026–27: Representation to CBDT

# Background

# Why the extension was requested The Foundation argues that the legal timeline presumes three conditions that did not hold for AY 2026–27: (a) account formats settled before year-end, (b) filing forms and utilities released early and stable, and (c) auditors having an uninterrupted audit window. The representation lists specific practical obstacles that, taken together, reduced the effective audit period and increased the risk of errors.

# Concrete grounds cited

• Late and revised ITR schemas and utilities. Several ITR forms (ITR-1, ITR-3, ITR-5, ITR-6) were released or revised late, with some revised as late as early or mid-September. Each revision forces software updates and revalidation because audit schedules must match ITR fields exactly.

• MCA filings pushed into September. The Ministry of Corporate Affairs' CCFS-2026 scheme ran until 15 September after a data-centre incident earlier in the year, producing urgent company filings that required CA time in early September.

• Religious festivals in September. Major Jain observances covered 18 of 30 days in September, during which proprietors, partners and staff observed restricted hours or closures, limiting access to records and confirmations.

• Heavy rain and localized flooding. Continuous rainfall in August–September caused waterlogging and utility disruptions in multiple states, restricting access to premises and records.

• Portal and system difficulties. Reports of login/OTP failures, DSC errors, validation problems with Form 3CD, delays in AIS/TIS/26AS data, and slow peak-hour portal responses added to delays.

• Cluster of other September compliance dates. Several routine monthly and statutory filings fall in September, increasing workload during the same compressed audit month.

# Legal basis and precedent

# Practical implication for taxpayers and auditors If no extension is granted, auditors and taxpayers face increased compliance strain in a shortened window, higher risk of mismatches between audit schedules and ITR fields, and potential filing errors. The Foundation frames the request as preserving audit quality and avoiding conflicts between religious observance and statutory compliance.

# Outcome reported elsewhere Subsequent reporting in related coverage indicates the CBDT did provide a relief extension (mentioned in later reports), but this representation documents the grounds submitted to justify such an extension.