The Madhya Pradesh Tax Consultants Association (MPTCA) has urged Union Finance Minister Nirmala Sitharaman to provide immediate relief from the compressed income-tax compliance calendar for Assessment Year (AY) 2026-27 by extending the due date for tax audit reports from September 30, 2026 to November 30, 2026.
In a representation dated September 21, 2026, the Association also sought extension of the due date for filing income-tax returns of assessees whose accounts are subject to audit from October 31, 2026 to December 31, 2026.
The representation, bearing Ref. No. MPTCA/DT/2026-27/17, has highlighted the practical difficulties being faced by taxpayers, Chartered Accountants, tax consultants, accountants and other professionals because of the compressed compliance schedule.
MPTCA Seeks Immediate Extension for AY 2026-27
According to the Association, the present compliance calendar has effectively left tax professionals with only a limited period to complete a substantial volume of tax-audit assignments.
MPTCA has requested the following extensions:
| Compliance | Present Due Date | Requested Due Date |
| Tax Audit Reports in Forms 3CA/3CB read with Form 3CD | September 30, 2026 | November 30, 2026 |
| Forms 10B/10BB and other consequential audit reports | September 30, 2026 | November 30, 2026 |
| Income-tax returns of audited business/profession cases | October 31, 2026 | December 31, 2026 |
| Other consequential reports/returns | As presently prescribed | Corresponding extension |
The Association has emphasised that the request is not for waiver of any tax liability but only for additional time to complete statutory compliance properly.
Association Says Effective Tax Audit Window Has Been Compressed
A major concern raised by MPTCA is the impact of the August 31, 2026 deadline for non-audit business and profession returns.
The Association noted that tax professionals who spend July and August completing a large number of non-audit returns are required to immediately shift to tax-audit assignments, with September 30 being the statutory deadline for filing tax audit reports.
As a result, the Association contends that the effective period available for completing tax audits has been compressed to approximately one month.
MPTCA stated that tax audit is not merely an online filing exercise. It requires examination of books and records, reconciliation of financial and tax information, verification of transactions and professional application of judgement.
The Association particularly highlighted the difficulties faced by smaller and medium-sized professional firms handling a large number of MSMEs, partnership firms, professionals, trusts and other taxpayers.
Tax Audit Requires Detailed Verification and Reconciliation
MPTCA has pointed out that preparation of a tax audit report involves examination of several categories of information.
These include books of account, financial statements, sales and purchase records, stock records, GST turnover, TDS and TCS records, Form 26AS, AIS and TIS, bank statements, loans and advances, statutory dues, fixed assets, related-party transactions and various disclosures required under Form 3CD.
The Association therefore argued that sufficient time is necessary for auditors to verify the information and prepare an accurate report.
According to MPTCA, an extension of the due date would not dilute the statutory requirement. Instead, it would provide taxpayers and professionals with adequate time to discharge the existing obligations accurately.
Progressive Availability of ITR Utilities Cited as Another Difficulty
The Association has also referred to the progressive availability and updating of income-tax return utilities for business and audit cases.
According to the representation, utilities for forms such as ITR-3, ITR-5 and ITR-6 became available progressively, with updates during the return-filing season.
MPTCA stated that tax audit and the corresponding income-tax return cannot be treated as completely independent processes because information reported in the audited financial statements and Form 3CD has a direct bearing on the corresponding ITR.
Therefore, the Association contended that the effective time available for completing both exercises is shorter than the statutory calendar may suggest.
Late Availability of TDS, TCS and SFT Information
MPTCA has further highlighted the time required to obtain and reconcile third-party information.
The Association pointed out that fourth-quarter TDS statements and annual SFT reporting take place after the end of the financial year. Information subsequently reflected in AIS, TIS and Form 26AS must then be reconciled with the taxpayer’s books and supporting documents.
According to the representation, taxpayers and professionals cannot simply rely on information appearing in AIS or Form 26AS without verifying it against the underlying records.
The Association has therefore argued that April and May cannot practically be treated as fully available months for completing tax audits because substantial third-party information is still being reported and reconciled during this period.
April to June Period Also Involves Finalisation of Accounts
MPTCA stated that the months immediately following the end of the financial year are substantially occupied with finalisation of accounts and collection of information.
The work includes preparation of financial statements, bank reconciliation, GST-related reconciliation, TDS/TCS reconciliation, obtaining certificates, reviewing AIS and TIS, verification of SFT information, debtor and creditor confirmations, stock records, fixed-asset schedules and statutory payment verification.
According to the Association, these activities consume considerable professional time before the tax audit can be completed.
July and August Remain Occupied With Return Filing
The Association further submitted that July and August are largely occupied with preparation and filing of non-audit income-tax returns.
With the deadline for relevant non-audit business and profession cases falling on August 31, professionals and their staff are required to handle substantial return-filing volumes before moving to tax-audit assignments.
MPTCA has argued that this creates a bottleneck because the same professional resources are required for both categories of compliance.
September Also Includes Holidays and Other Professional Commitments
The Association has also pointed out that September cannot be treated as a completely uninterrupted working month.
Tax audit requires coordination between Chartered Accountants, taxpayers, accountants, employees, bankers, GST professionals and other advisers. The availability of these stakeholders can be affected by holidays and other professional commitments.
According to MPTCA, this makes a one-month effective audit window particularly challenging.
Overlapping Statutory and Professional Assignments
Another ground cited in the representation is the simultaneous nature of several professional assignments.
According to MPTCA, Chartered Accountants and tax professionals may also be engaged during the same period in statutory audits, GST reconciliations, Forms 10B/10BB, MCA compliances, internal audits, TDS/TCS matters, certifications and other assignments.
The Association has therefore submitted that retaining only September for a large volume of tax-audit work places considerable pressure on the profession.
Revised Financial Reporting Requirements Increase Workload
MPTCA has also referred to revised financial-reporting requirements applicable to non-corporate entities and LLPs.
The Association stated that the revised requirements involve additional work relating to presentation, classification and disclosures in financial statements.
For entities becoming subject to the revised requirements, professionals may need to devote additional time to preparing and reviewing financial statements, including comparative information.
The Association has urged that these additional requirements also be considered while assessing the practical time available for completing tax audits.
Transition to Income-tax Act, 2025 Adds to Compliance Burden
The representation also refers to the transition to the Income-tax Act, 2025 and the associated rules.
MPTCA has submitted that tax professionals are currently required to deal with ongoing proceedings and compliances under the Income-tax Act, 1961 while simultaneously familiarising themselves with the new legislative framework.
The Association referred to continuing processes under the 1961 Act, including return filing, assessment, reassessment, appeals and notices, alongside the implementation of new procedures and compliances under the Income-tax Act, 2025.
According to MPTCA, professionals therefore need to devote time to training staff, understanding the new provisions and educating taxpayers about the transition, further reducing the time available for completing AY 2026-27 tax audits.
AIS, TIS and 26AS Reconciliation Also Requires Time
MPTCA has stressed the importance of reconciling information appearing in AIS, TIS and Form 26AS with the taxpayer’s books and underlying records.
The Association noted that AIS contains multiple categories of financial information, including TDS/TCS and SFT-related information, tax payments and other information received by the tax department.
The representation argues that such information cannot always be mechanically incorporated into an income-tax return. Differences between third-party information and the taxpayer’s books may require verification and reconciliation.
MPTCA Questions Practical Benefit of One-Month Gap Between Audit and ITR Due Dates
The Association has also proposed a change in the existing structure under which the tax audit report is due one month before the corresponding audited income-tax return.
According to MPTCA, tax audit and return preparation are closely interconnected and are often undertaken simultaneously.
The Association has therefore suggested that the Tax Audit Report and the audited income-tax return should ultimately have the same due date.
For future years, MPTCA has proposed October 31 as the common due date for both the Tax Audit Report and the audited ITR.
Extension Would Not Affect Tax Liability, Says Association
MPTCA has submitted that the requested extension would only provide additional time for compliance and would not result in any waiver or postponement of the underlying tax liability.
According to the Association, taxpayers would remain responsible for advance tax, self-assessment tax, applicable interest and other statutory liabilities.
The Association has further stated that additional time could help improve the accuracy of tax reporting and reduce the possibility of defective returns, subsequent corrections and litigation arising from inadvertent errors.
MPTCA Seeks Permanent Rationalisation of Compliance Calendar
Apart from immediate relief for AY 2026-27, MPTCA has proposed a permanent restructuring of the income-tax compliance calendar from AY 2027-28 onwards.
The Association has suggested that TDS/TCS and SFT reporting should be advanced so that relevant information becomes available to taxpayers and professionals earlier in the year.
In particular, it has proposed that TDS/TCS and SFT information should preferably become available by April 30.
The objective, according to the representation, is to facilitate earlier reconciliation of third-party information and allow tax professionals to begin audit and return preparation with more complete data.
Proposed Three-Tier Return Filing Calendar
For future years, MPTCA has suggested the following structure:
| Category | Suggested Due Date |
| Non-business / non-audit assessees | June 30 |
| Business/profession assessees not liable to audit | July 31 |
| Tax-audit / audited business and profession cases | October 31 |
The Association believes that such a structure would create a more predictable compliance cycle and provide professionals with a meaningful period for tax-audit assignments.
Tax Audit Report and Audited ITR Proposed for October 31
One of the principal long-term recommendations made by MPTCA is to align the Tax Audit Report and audited ITR due dates.
Under the Association’s proposal, both would be due on October 31.
MPTCA has stated that this would eliminate the existing one-month gap and reflect the practical reality that audit and return preparation are interdependent processes.
The Association has further submitted that a rationalised calendar would reduce the need for professional bodies to seek extensions every year.
Association Seeks Predictable Compliance Calendar
MPTCA has emphasised that the issue is not limited to professional convenience but concerns the quality and reliability of statutory tax reporting.
The Association stated that tax audit reports are professional attestation documents requiring adequate examination of financial records, statutory compliances, third-party information and applicable legal provisions.
It has accordingly urged the Finance Ministry to consider a compliance calendar that provides adequate time for professional verification while ensuring timely tax administration.
