As the prescribed due date for furnishing of TDS statement for the Quarter 1 of the Financial Year 2020-21 is around the corner, that is, July 31, 2020, there is a chaos to know about the applicable due date. Whether it will be the original due date of 31-07-2020 as per Rule 31A or 31-03-2021, the due date extended for all compliances (falling between 20-03-2020 to 31-12-2020) by the Notification No. 35/2020, dated 24-06-2020. We have tried to solve this controversy in this write-up

1. W a a TDS a Q1 F a c a Y a 2020-
21?
E a a
To give relief from the compliance burden during the Covid-19 pandemic, the CBDT
has given relaxation in various compliances. The Govt. ide he Ta a ion and O her La s
(Rela a ion of Cer ain Pro isions) Ordinance, 2020 read with No ifica ion No. 35 /2020, da ed
24-06-2020 has extended various due dates of Income-tax compliances. It includes the
extension of due dates for filing of Income-tax Returns for the Assessment Year 2019-20
and 2020-21, TDS/TCS statement of the 4th quarter of Financial Year 2019-20, etc.
The Notification has specificall provided that the due dates for completing an
compliance shall be 31-03-2021 if it falls during the period from 20-03-2020 to 31-12-2020
except those specified in the Pro iso to Notification No. 35/2020. Clause (iii) to the said
Pro iso creates an exception that the TDS/TCS statement for the month of Februar or
March, 2020, or for the quarter ending on the 31st da of March, 2020, as the case ma
be, the due date shall be extended to the 31st da of Jul , 2020. The Notification did not
mention an thing about the due date for filing of TDS/TCS Statement for Q1 and Q2 of
the financial ear 2020-21. As the prescribed due date for furnishing of TDS statement
for the Quarter 1 of the Financial Year 2020-21 is around the corner, that is, Jul 31, 2020,
there is a chaos to know about the applicable due date. Whether it will be the original
due date of 31-07-2020 as per Rule 31A or 31-03-2021, the due date extended for all
compliances (falling between 20-03-2020 to 31-12-2020) b the Notification No. 35/2020,
dated 24-06-2020.
Bases literal interpretation1 of the Notification, it is reasonable to conclude that the due
dates of all compliances falling between 20-03-2020 to 31-12-2020 have been extended to
31-03-2021. This extension is not available for all those compliances which are
mentioned in the Pro iso to the said notification. In the absence of reference of the due
date for filing of TDS statement for Q1 of FY 2020-21, it could be concluded that the due
1
One of the well-recognised canons of construction is that the Legislature speaks its mind b use of
correct expression. If there is no ambiguit , it would mean that the language used speaks the mind of the
legislature and there is no need to look somewhere else to discover the intention or meaning. See
Prithipal Singh Bedi v. Union of India AIR 1982 SC 1413 and CBDT v. Adit a V. Birla [1988] 36 Taxmann
9 (SC).

2. date should be 31-03-2021. However, the purposive interpretation suggests otherwise.
The due date for filing of TDS Statement for Q1 and Q2 falls be ond the due date for
filing of TDS Statement of Q3. If the literal interpretation of the Notification is applied
the deductor gets time till 31-03-2021 to furnish TDS statements for Q1 and Q2 but for
Q3 he is required to furnish the statement b 31-01-2021 as this due date is not falling
between the stated duration of 20-03-2020 to 31-12-2020. This will create an un ielding
situation for the tax deductors as the have to prepare and submit TDS statement of Q3
much before the due date of furnishing TDS statements of Q1 and Q2 of Financial Year
2020-21.
Further, in the absence of an announcement of a change in the TDS utilit , the CPC
ma automaticall charge the late filing fees of Rs. 200 per da if TDS statement is not
filed on or before 31-07-2020.
Thus, it is advisable that the deductors should follow the original prescribed limitation
period as far as the due dates for filing of TDS/TCS Statement for Q1 and Q2 of FY
2020-21 are concerned.
It should be noted that the Notification no. 35 did not provide an relaxation with
respect to the pa ment of tax. In absence of an relaxation of pa ment of tax, no
concessional interest rate shall be available to a taxpa er for making dela ed pa ment
of TDS, TCS or Advance-tax. The taxpa er is required to deposit tax with the Central
Government on respective due dates to avoid an interest charges. This also supports
the conclusion that there is no extension in the due date.
The last reasoning to support this conclusion is the due date for issuing the TDS/TCS
Certificate. Rule 31 provides that the TDS Certificate is required to be issued b the
deductor on a quarterl basis within 15 da s from the due date of furnishing the
statement of TDS. If literal interpretation is believed, the deductor will be required to
issue the certificate b 15-04-2021 for Q1 and Q2 and b 15-02-2021 for Q3. This will
create a situation of havoc for the deductees as the will not get an confirmation about
the deposit of tax deducted b the deductor.
One of the well-recognised canons of construction is that a law has to be read as it is
written in the document. Thus, a literal interpretation of Notification No. 35 read i h
the Ordinance suggest that the due date for furnishing of TDS statement for Q1 and Q2
of Financial Year 2020-21 stands extended to 31-03-2021. It is recommended that the
CBDT should issue a clarification to rest the controvers .
Please refer he ar icle for de ailed anal sis on he no ifica ion

3. Attach Documents
Attach related files with Challan/Employee/Transaction - Attachment of file option
is given in the Employee/deductee form
Export & Import
Bulk challan Export
Excel import and export feature for preparing correction statement with lesser effort
Import Data from Excel files
Interest Calculator
Calculator for computing Interest on late deposit of TDS
TRACES
TRACES login interface integrated in the software (Requisition of conso (.tds) or
Forms 16A & 27D)
All Certificates validations through TRACES in single shot
Get Challan option - to fetch challans for a specified period from TRACES
Add Challan option to add challan in TRACES account (for correction statement C9)
Tax deduction as per new tax regime (Section 115BAC)
Functionality to calculate tax to be deducted on salary as per new Tax regime
u/s 115BAC as well as old tax regime.
Deductors/Master
Unlimited Deductors/Companies, Deductee & Employees
Grouping of Master - Different organizations can be grouped
Default Predictor Notice
Check for Default Notice-Corrective actions can be taken in advance and file fully
compliant e-TDS statement. Save additional cost in interest on delayed deposit
and delayed deduction. Save yourself from trouble of attending to notices and
filing appeals
Dr. Vinod K. Singhania
Dr. Kapil Singhania

4. Verifications
Run time verification of challan (optional)
File Validation & Generation
Instant display of file validation errors
Option to download .csi file during file validation
FVU file generation for return submission in just one click
Forms/Reports
Auto Generation of Form 12BA
Generate almost all forms of eTDS/eTCS Return, i.e., 24Q, 26Q, 27Q & 27EQ
MIS report for Invalid PAN/Late Payment
Facility to Check Quarter-wise transaction of Deductees
TDS certificates like Form 16/Form 16A can directly be downloaded from TRACES
Backup
Ability to save backup online using cloud services like dropbox
Backup option is given 1. Organization-wise 2. Year-wise 3. Full Backup
Easy process to file revised return
Very easy process to file correction statement
Step by step guide to file correction statement is also provided
Useful statutory information like tax rates
Various useful statutory information related to TDS also provided to update
knowledge about recent updates
Easy data migration through .tds files
Data can easily be migrated with “Import from .tds files” option.

5. Price
5700 [Single User]
8100 [MULTI USER]
(Excluding GST)

6. InthemonthofMarch2020,theFinanceMinister,Smt.NirmalaSitharaman,
held a press conference to announce various measures to address the
concerns relating to statutory and regulatory compliance. To give effect to
such announcement, the Taxation and Other Laws (Relaxation of Certain
Provisions) Ordinance, 2020 (hereinafter referred to as ‘Ordinance 2020’)
was promulgated by the President of India.
The Ordinance had provided for the extension of various time-limits
under the Taxation and Benami Acts. It also provided for the extension of
issued under these Acts. Considering the situation arising out of COVID-19
pandemic, the Govt. has decided to further extend the due dates for
various compliances for the previous years 2019-20 and 2020-21 vide
said provisionempowers the Central Government to specify the new cut-
provides a new cut-off date ofcompliances which stands extended to a
Taxmann’s Editorial Team

7. 2019-20, etc.
no penalty and prosecution would be levied for such delayed compliance.
This relaxation has been provided only in respect of taxes which are due
Central Govt. to extend the due date. In absence of any announcement
shall be available to a taxpayer for making delayed payment of TDS, TCS
below tables.
Taxmann Review Bulletin | June 2020 02
(i) the 31st day of December, 2020 shall be the end date of the period
(ii) the 31st day of March, 2021 shall be the end date to which the
time limit for completion or compliance of such action shall stand
extended.
“
“

8. Section 1
a report of transfer pricing (TP)
accounts audited under the
Incometax Act or under any other law
(b) In response to a notice issued
2
2
Note:
05

9. with Rule
Rule
to November, 2020 of month in which
tax is deducted
3
read with
during February 2020
during March 2020
with rule
read with
the month
2019-20 can be issued till 15-08-2020.
Taxmann Review Bulletin | June 2020 06

10. 09
read with Aadhaar number
(The extension has been given in those cases
where the due date falls between
authorities, commissioners or tribunal.
(The extension has been given in those
cases where the due date falls between
furnishing of any report, document etc.
(The extension has been given in those
cases where the due date falls between
7
Vivad se payment of disputed tax .
Vishwas
Act, 2020
of time.

11. Taxmann Review Bulletin | June 2020 10

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