ICAI Seeks Extension of Tax and Audit Filing Deadlines and Auto-Renewal for Trusts

The President of ICAI (Institute of Chartered Accountants of India), CA Charanjot Singh Nanda, has recently sent a representation (ICAI/DTC/2025-26/Rep-11), dated September 17, 2025, addressing the Chairman of the Central Board of Direct Taxes (CBDT), Shri Ravi Agrawal. The letter highlights important issues faced by taxpayers and charitable institutions and requests the government’s support in resolving them. The representation made requests for the following:

• Taxpayers should get some relief in return filing due date and specified dates.
• For small trusts and institutions whose registration is ending on or after 31st March 2026, the renewal should be automatic or deemed renewed.
• Other trusts, whose last date to apply for renewal is September 30, 2025, should also be given the same benefit of parity and relaxation.

1. Request for parity for taxpayers in respect of the return filing and other due dates, and the specified date

With this, ICAI began the representation by saying that this financial year, the Income Tax Return (ITR) forms and related utilities were released much later in comparison to the previous financial year. Some ITR forms were made available to file in July and August 2025, which left taxpayers and auditors with plenty of time to prepare and file their returns. Despite the fact that the government has extended the due date for filing the income tax return (ITR) from July 31, 2025, to September 15, 2025 (last extended till September 16), there is no relief for taxpayers who are due to file their returns on or before 31st October 2025. Additionally, the audit-related forms (3CA-3CD/3CB-3CD) were released late in July 2025.

Since the law prescribes a clear gap between different filing deadlines, ICAI requests CBDT to immediately extend the return filing due date of 31st October 2025 and the specified date of 30th September 2025 under Section 44AB to maintain fairness and give taxpayers enough time.

2. Auto-Renewal for Small Charitable Trusts

ICAI also raised concerns about renewal requirements for charitable trusts and institutions. Under the current law, trusts registered from April 1, 2021, must apply for renewal six months before their registration expires in 2026. This means applications have to be filed by September 30, 2025.

However, the Finance Act, 2025, has already extended the validity of registration for small trusts from 5 years to 10 years for those having income upto Rs. 5 crore. ICAI has therefore suggested that these small trusts should automatically get their registrations extended without having to apply again.

For other trusts and institutions whose renewal is also due on September 30, 2025, ICAI has requested that the government provide parity by extending their deadline as well, in line with the changes sought for income tax return filing.

Representation given below for referance: