List of due dates not extended and relaxations not granted by the Government vide Press Release dated 24 March 2020

Sr No	Particulars	Consequences	Action Points
1	Due date for payment of TDS for the month of March 2020 has not been extended. Relief has been granted with respect to interest to be charged for the default.	Interest at 9% p.a. will be applicable with respect to delayed payment of TDS upto 30 June 2020. Also, there is no immunity from prosecution for non-deposit of TDS within the due date. There is a good case to argue that there was a sufficient cause for the delay but the acceptance of the same will be at the discretion of the officer/ Court.	TDS for the month of March 2020 should be paid by 30 April 2020 in order to avoid interest payment/ prosecution proceedings.
2	Due date for filing revised income tax return for FY 2018-19 has not been extended	It could be argued that all due dates falling within the period of 20 March 2020 to 29 June 2020 have been extended to 30 June 2020. However, in absence of any clarification on the same, there is a possibility that the portal may not accept revised returns post 31 March 2020.	Hence, it is advisable to file revised return on or before 31 March 2020 in order to avoid unnecessary hardship.
3	No embargo on recovery proceedings under income-tax or GST law	Contrary to the submission of the Solicitor General to the Supreme Court last week, there is no embargo with respect to recovery proceedings.	Not a lot can be done to prevent attachment of bank account except trying to stay in touch with the concerned officer and bank officials.
4	No embargo on survey or search proceedings under income-tax or GST law	There is a risk of community spread of coronavirus – to the families of the concerned officials and to the family members/ neighbors residing at the place where survey/ search is carried out	Nothing can be done to prevent this

Sr No	Particulars	Consequences	Action Points
5	Manner of calculation of interest under Section 234B (default in payment of advance tax) for FY 2019-20 has not been amended. Relief has been granted with respect to interest to be charged for the default.	In case 90% of income-tax is not discharged by 31 March 2020, interest at 9% p.a. will be charged upto 30 June 2020 and beyond that 12% p.a. interest will be charged.	Advance tax for FY 2019- 20 should be discharged by 31 March 2020 in order to avoid interest payment.
6	Due dates with respect to various compliances under the Foreign Exchange Management Act, 1999 (‘FEMA’) have not been extended.	In case compliances under FEMA are not completed within the due date, there may be penal consequences. There may also be penal consequences if the compliance is completed by the entity but is pending with the bank (e.g. SMF – FC GPR etc)	As far as practically possible, compliances under FEMA need to be completed. If the bank is unable to complete the same at their end, e-mails should be written to the banks for follow-up – this will help in justifying the delay to Reserve Bank of India.
7	Due date for filing GSTR 3B for the months of February, March and April 2020 for taxpayers having turnover of Rs 5 crores or more has not been extended. Relief has been granted with respect to interest, late fee and penalty for the default.	If taxpayers having turnover of Rs 5 crores or more do not file GSTR 3B and consequently not make GST payment for the months of February, March and April 2020 by the due date, interest will be charged at 9%. Late fee and penalty will be waived.	In order to avoid interest liability, GSTR 3B needs to be filed on or before the respective due date for the months of March and April 2020.
8	The operation of Rule 36(4) of the CGST rules has not been suspended. Rule 36(4) requires that only that much Input Tax Credit (increased by 10% of credit reflecting) as is shown in GSTR 1 by the vendor can be claimed while paying GST.	The due date for filing of GSTR 1 for all taxpayers for the month of March, April and May 2020 (for those who have opted for monthly returns) has been extended to 30 June 2020. In such a situation, no taxpayer will file GSTR 1 – resulting in the recipient being unable to claim ITC.	In these cases, gross GST liability will be required to be paid in order to avoid interest/ other consequences.