The Rajasthan Tax Consultants Association (RTCA) has urged the Union Finance Ministry and the Central Board of Direct Taxes (CBDT) to extend the deadline for furnishing tax audit reports and Forms 10B and 10BB for Assessment Year 2026-27 from September 30, 2026, to October 31, 2026.
In a representation dated September 8, 2026, the Association highlighted the limited effective time available to complete tax audits, continuing changes to income-tax return utilities, technical difficulties on the e-filing portal, revised financial-reporting requirements and disruptions caused by heavy rainfall and flood-like conditions.
The representation was addressed to the Union Finance Minister, the CBDT Chairman and the Principal Chief Commissioner of Income Tax, Rajasthan.
The Association has specifically sought an extension for furnishing tax audit reports in Forms 3CA and 3CB along with Form 3CD. It has also requested that the deadline for submitting audit reports in Forms 10B and 10BB be extended to October 31, wherever applicable.
In addition, the RTCA has asked the authorities to suitably align consequential compliance requirements, including the due date for filing income-tax returns, wherever necessary.
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According to the Association, the deadline for filing income-tax returns in non-audit cases for Assessment Year 2026-27 was August 31, 2026, while the due date for furnishing tax audit reports remains September 30, 2026.
This effectively leaves tax professionals with only the month of September to complete audit-related work after concluding the non-audit return filing season, it submitted.
The Association stressed that a tax audit is not limited to uploading Forms 3CA or 3CB and Form 3CD. It requires a detailed examination of books of account, supporting documents, bank statements, GST records, TDS and TCS records, Annual Information Statement and Taxpayer Information Summary data, stock records, fixed assets, related-party transactions and other statutory disclosures.
The compressed schedule has consequently placed an exceptionally heavy workload on taxpayers and professionals, the representation stated.
Frequent Updates to ITR Utility Cited
The RTCA also drew attention to the release and continued modification of the income-tax return utilities for Assessment Year 2026-27.
It stated that the common ITR utility was initially released on May 20, 2026, and continued to undergo changes, with version 1.2.4 released as recently as September 2, 2026.
Since the tax audit report and the corresponding income-tax return are closely connected, professionals require stable return forms, schemas and validation systems before they can finalise audit disclosures, the Association said.
Frequent changes leave little time for testing, reconciliation and error-free filing before the statutory deadline, it added.
E-Filing Portal Problems Affect Audit Completion
The representation further referred to technical difficulties faced by taxpayers and professionals while using the Income Tax Department’s e-filing portal.
These include problems involving login access, retrieval and reconciliation of AIS and TIS information, digital signatures, form validation, uploading of documents and filing of returns.
The Association maintained that such interruptions have a cascading effect in audit cases because every disclosure must be independently checked and reconciled before the report is furnished.
Technical instability, when combined with the limited statutory timeline, increases the risk of inadvertent errors and incomplete disclosures, it said.
Revised Reporting Format Requires Additional Work
Another ground cited in support of the extension is the implementation of the Institute of Chartered Accountants of India’s Guidance Note on Financial Statements of Non-Corporate Entities.
The Association said that under the ICAI announcement dated March 31, 2026, the first phase applies to accounting periods beginning on or after April 1, 2025, for entities with a turnover exceeding ₹5 crore.
The revised formats, disclosures and presentation requirements require additional time for preparing, reviewing and finalising financial statements. This, in turn, directly affects the tax audit process, it submitted.
Heavy Rainfall and Flood-Like Conditions Disrupt Work
The RTCA also highlighted the effect of heavy rainfall, waterlogging and flood-like conditions across various districts of Rajasthan and other parts of the country.
According to the representation, adverse weather has disrupted normal business operations and restricted access to records. It has also affected the movement of taxpayers and professionals, physical verification exercises and stock-related audit procedures.
The Association argued that enforcing a uniform deadline without accounting for extraordinary local conditions would cause genuine hardship to affected taxpayers and professionals.
Festive and Business Season Adds to Compliance Pressure
The September-November period coincides with major festivals such as Navratri, Dussehra and Diwali, the RTCA pointed out.
This period is generally associated with increased commercial activity, including higher sales, purchases and inventory movement. Businesses are therefore occupied with day-to-day operations, making it more difficult for professionals to obtain complete records and finish audit procedures within the existing deadline.
Extension Necessary to Maintain Audit Quality: RTCA
Emphasising that tax audit is a substantive statutory responsibility rather than a procedural formality, the Association said tax auditors are required to examine books of account and make numerous factual and legal disclosures in Form 3CD.
These disclosures can have significant consequences for both taxpayers and the tax administration.
The present timeline is forcing professionals to work under extreme pressure, including extended working hours and work throughout weekends and holidays, the RTCA said.
A reasonable extension would enable auditors to properly verify and reconcile information and furnish complete, accurate and reliable reports. Such relief would ultimately serve the interests of both the Revenue and taxpayers, it added.
The representation has been signed by RTCA President CA Ratan Goyal and General Secretary CA G.P. Gupta. The Association, established in 1976, stated that it represents approximately 1,800 chartered accountants, tax advocates and other tax professionals across Rajasthan.
The RTCA has requested the Finance Ministry and the CBDT to grant the extension at the earliest so that taxpayers and professionals can complete the entire compliance process smoothly, accurately and meaningfully.
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