Submission of Return FY 2019-20 AY 2020-21

As most of you are aware the date for submission of your return of income was extended from July 31, 2020 to October 31, 2020 in the first quarter of this calendar year.

Along with that extension the date for submission of audit reports was extended from September 30, 2020 to October 31, 2020 and for those of you whose accounts are audited the return of income was to be submitted by November 30, 2020. Both the audit reports and the return received an extension by one month from the original date.

Recently, on September 18, 2020,  the Government introduced a bill – ‘The Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Bill, 2020’. The bill received the assent of Parliament on September 22, 2020.

Section 3(1)(c) of the said bill extends the due date for various compliances under Specified Acts to 31st March 2021.

However, the 3rd proviso of section 3(1)(c) provides an exception to this and states that in case of due date for filing Income Tax Returns for AY 2019-20 30th September 2020 is to be substituted in place of 31st March 2021 and in case of due date for filing Income Tax Returns for AY 2019-20, 30th November 2020 is to be substituted in place of 31st March 2021.

Hence the due date for filing Income Tax Returns for:-

  • AY 2019-20 (FY 2018-19) is 30th September 2020,
  • AY 2020-21 (FY 2019-20) is 30th November 2020 and
  • Due date for filing audit reports of AY 2020-21 would be 31st October 2020

The bill therefore has not provided any relief in terms of the due date of filing the return of income.

Relief has been provided where the date has been extended to 31st March, 2021 in respect of:

  1. completion of any proceeding (viz. Assessment, Reassessment, Rectification, Search , Survey and Seizure , Demand & Recovery or similar proceedings etc,) or passing of any order (viz. Assessment Order under section 143(3) or section 144 or section 263 or section 264 or similar order etc.) or issuance of any notice, intimation, notification, sanction or approval, (viz. Penalty Notice, Notice of recovery, attachment , 12AA sanction or approval or similar communications etc) or such other action ( viz. Valuation report , Valuation Reference and/or Internal reports/documentation or similar etc), by whatever name called, by any authority, commission or tribunal, by whatever name called, under the provisions of the specified Act; or (viz. all specified Income Tax Authorities under the provisions of the Income Tax Act 1961)


  1. filing of any appeal, reply or application or furnishing of any report, document, return or statement or such other record, by whatever name called, under the provisions of the specified Act; or (viz. Before CIT ( Appeals), Tribunals, High Courts as well as Supreme Court or any other designated appropriate authorities etc. under the provisions of Income Tax Act 1961)


  1. and some other reliefs which have been summarised in the table below


A provision has been made that the Central Government may specify different dates for completion or compliance of different actions. (Proviso explains that Central Govt may specify different dates other than above dates specified)

Summary of Important Amendments


Financial Year/Previous Year


Due Date


Due Date


Income Tax Return for the period 01.04.2018 to 31.03.2019




Income Tax Return for the period 01.04.2019 to 31.03.2020




All Kind of Audit Reports for the period 01.04.2019 to 31.03.2020




TDS Returns for the quarter ending 30.06.2020 & 30.09.2020 only. Please note it is not extended for quarter ending 31.12.2020




Any kind of Appeal filing under the provisions of the Income Tax Act 1961




Investment in Section 54 to 54GB if due between 20.03.2020 to 29.09.2020




Investment in 80C Limits for FY 1819




All other Compliances under the provision of Income Tax Act 1961




Pending E Verification of previous years ITRs




Aadhaar Linking with PAN Number




GSTR 9, 9A and 9C – FY 2018-19





In future, CBDT may issue further notifications for the extension of due dates but as of today no due dates as notified u/s 139 of the Income Tax Act 1961.

Multiple representations have already been made to the Finance Minister for extension.



  1. To those of you who have not submitted to us your papers for tax returns please do so at the earliest.
  2. To those of you for whom we need to conduct audits please inform us of your state of preparedness so we can plan for the audit.

Due to disconnected working and poor internet connectivity we have been facing some delays but considerable work has been completed in respect of those clients who have submitted papers to us. We should be able to close and submit these returns in the next 2-3 weeks.

We are working hard to ensure that all your returns are filed in time, i.e. before the due dates.

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