14 Compliance Dates Extended – What is not Extended?

 

As expected, the CBDT vide its Circular NO. 16/2021 has extended the compliance date for 14 compliance. The circular issued by the CBDT says that the dates are extended in view of the “Difficulties reported by the taxpayers and other stakeholder in electronic filing of certain forms…..”.

The correct preface would have been “In view of the problem created by Infosys….In view of the untimely launching of the new income tax portal… … In view of …..etc etc”.

Jokes apart, let us know what is done and what is not done by the above circular.

The dates of following 14 compliance has been extended by above circular:

1. The due date for registration of trust which was due on 31.08.2021 has been again extended up to 31/03/2022.

2. The due date for final registration u/s 12A, 80G, 10(23C) which falls on or before 31.08.2022 is also extended to 31/03/2022.

3. The due date for filing of Return of Equalization Levy Statement in Form No. 1 for the FY 2020-21 is also extended to 31/12/2021 from 30.06.2021.

4.  The Due date of filing of quarterly statement by authorized dealer in respect of remittances made for the quarter ending on 30/06/2021 in Form No. 15CC is also extended to 30/11/2021. The earlier extended due date was 31/08/2021.

5. The Due date of filing of quarterly statements by authorized dealers in respect of remittances made for the quarter ending on 30/09/2021 in Form No. 15CC is also extended to 31/12/2021. The normal due date was 15/10/2021.

6. The due date for uploading of declaration in Form No. 15G & 15H for the quarter ending on 30/06/2021 is also extended to 30/11/2021 from earlier already extended dates of 31/08/2021.

7.  The due date for uploading of declaration in Form No. 15G & 15H for the quarter ending on 30/09/2021 is also extended to 31/12/2021. The original due date for this submission was 15/10/2021.

8. Intimation required to be made by Sovereign Wealth Fund in respect of Investment made in India in Form II SWF for the quarter ending 30/06/2021 is also extended to 30/11/2021. Earlier, it was extended to 30/09/2021.

9. Intimation required to be made by Sovereign Wealth Fund in respect of Investment made in India in Form II SWF for the quarter ending 30/09/2021 is also extended to 30/12/2021. Original due date for its filing was 15/10/2021.

10. Intimation to be made by a pension fund in respect of each investment made by it in India in form No. 10BBB for the quarter ending on 30/06/2021 is also extended to 30/11/2021. Earlier, it was extended to 30/09/2021.

11. Intimation to be made by a pension fund in respect of each investment made by it in India in form No. 10BBB for the quarter ending on 30/09/2021 is also extended to 31/12/2021. Original due date for its filing was 31/10/2021.

12. Intimation by a constituent entity resident in India of an international group, the parent entity of which is not resident in India for the purpose of Section 286(1) in Form No. 3CEAC has also been extended to 31/12/2021. The original due date for its filing was 30/11/2021.

13. Report by a parent entity or an alternate reporting entity or any other constituent entity resident in India for the purpose of Section 286(1) in Form No. 3CEAD has also been extended to 31/12/2021. The original due date for its filing was 30/11/2021.

14. Intimation on behalf of an international group for the purpose of proviso to Section 286(4) in Form No. 3CEAE under Rule 10DB has also been extended to 31/12/2021. The original due date for its filing was 30/11/2021.

What is NOT EXTENDED so far:

1.  The due date for filing of Income Tax Return which was earlier extended to 30/09/2021 has not been extended.

2. The due date for payment of Advance Tax remains the same and is not extended.

3. The due date for payment of TDS/TCS has not been extended.

4. The due date for getting the books of accounts audited and its uploading thereafter has not been extended.

5. The due dates for compliance with the provision related to Non Filers of Income Tax Returns has not been extended.

6. The due dates for filing of appeal with CIT (A) or ITAT have also not been extended.

7.  The due dates of all compliance falling due after 31/12/2021 have not been changed in any way.

8. The due date for filing of Quarterly TDS & TCS returns has also not been changed.

9. The dates for filing return u/s 148 (which is required to be filed within the time limit specified in the notice itself, normally 30 days) has also not been extended.

MOST IMPORTANTLY – WHAT NEED TO BE EXTENDED:

The dates for implementation of the New Portal needs to be EXTENDED. The easiest way is to defer the implementation schedule of the new portal and keep the original dates of compliance intact. For the sake of ONE, everyone is getting penalized.

I humbly appeal that the well settled, tried & tested income tax portal be restored in the interest of our country. The old portal was one of the finest portals the country has witnessed. There is no parallel to the old portal which has evolved in a fabulous way over a period of time.

There is enough trial and error that has been done with the GST Portal, MCA portal, etc. Let us restore the old income tax portal back.