Belated and revised ITR sheet for CA firms: which clients to file or fix by 31 December 2026, and what changes on 1 January (AY 2026-27)
What you get: a ready-to-copy Google Sheet layout with one row per client whose AY 2026-27 (FY 2025-26) income-tax return is missing or wrong. Formulas give each row its route and its cost: "Belated return u/s 139(4) by 31 Dec", "Revise u/s 139(5) by 31 Dec (no 234-I fee)", "Revise by 31 Mar 2027 with 234-I fee" or "Updated return (ITR-U) only", the fee in rupees, and warnings for the three things a late return quietly loses. Plus a plan to 31 December, three made-up example rows and two client messages. Free, no sign-up.
Short answer (checked 22 Oct 2026): AY 2026-27 is still governed by the Income-tax Act, 1961 (department's FAQs on interplay and transition, Q3.7–3.8). A client who missed the section 139(1) due date can file a belated return up to Thursday 31 December 2026, or before the assessment is completed if that is earlier, with a section 234F fee of ₹5,000, or ₹1,000 where total income does not exceed ₹5 lakh. A client who filed and found an omission or wrong statement can file a revised return: the Finance Act, 2026 substituted section 139(5) so revision is allowed up to the end of the assessment year (31 March 2027) or completion of assessment, whichever is earlier, subject to the new section 234-I fee (₹1,000 / ₹5,000 on the same ₹5 lakh test), which the department's return of income page applies to revised returns furnished more than nine months after the end of the financial year: for FY 2025-26, from 1 January 2027. So 31 December 2026 is the last day for every belated return and the last fee-free day for revisions. This is a starting point, not tax advice.
The four routes, with dates for AY 2026-27
| Situation | Route | Last date | Fee |
|---|---|---|---|
| Return not filed by the section 139(1) due date | Belated return, section 139(4) | Thu 31 December 2026 (or completion of assessment, if earlier) | Section 234F: ₹5,000; ₹1,000 if total income does not exceed ₹5 lakh |
| Return filed (on time or belated), then an omission or wrong statement found | Revised return, section 139(5) | Thu 31 December 2026 without the new fee | None under section 234-I |
| Same, but found later | Revised return, section 139(5) | Wed 31 March 2027 (or completion of assessment, if earlier) | Section 234-I from 1 January 2027: ₹1,000 if total income does not exceed ₹5 lakh, else ₹5,000 |
| Both windows closed, and the correction increases tax | Updated return (ITR-U), section 139(8A) | Within 48 months from the end of the assessment year (31 March 2031) | Additional tax under section 140B: 25% of tax plus interest within 12 months from the end of the assessment year, then 50%, 60% and 70% for each later year |
Only a return filed under section 139(1) or a belated return under section 139(4) can be revised; a return filed in response to a section 142(1) notice cannot be revised under section 139(5) (return of income page). An updated return cannot be a return of a loss (except where it reduces a loss), cannot reduce tax, and cannot create or increase a refund. That last rule is why a missed deduction or missed TDS credit has to be fixed through a revised return by 31 March 2027: after that, there is no route to claim it.
Tab "clients": one row per client with a missing or wrong AY 2026-27 return
| Column | What goes in it |
|---|---|
| A Client | Name |
| B Due-date category | 1 = section 92E (transfer pricing) case, 2 = company or audit case, 3 = business or profession without audit, 4 = everyone else (Explanation 2 to section 139(1)) |
| C 139(1) due date | Formula below; overwrite it if a CBDT extension applies to that client's category |
| D Original return filed on | Date, or blank if nothing filed yet |
| E Filed under | 139(1), 139(4), 142(1), or blank |
| F What is wrong | Free text, for example "FD interest of ₹48,000 in AIS not in return" or "Not filed: documents came late" |
| G Type | Not filed / Income missed (tax goes up) / Deduction or TDS missed (refund goes up) / Wants old regime / Has a loss to carry forward |
| H Total income after the fix (₹) | Number (drives the ₹1,000 / ₹5,000 fee) |
| I Route | Formula below |
| J Fee if filed today (₹) | Formula below |
| K Warnings | Formula below |
| L Documents received on | Date |
| M Filed on / acknowledgement no. | Text |
| N e-verified on | Date (a return is not complete until it is verified) |
C2: =CHOOSE(B2,DATE(2026,11,30),DATE(2026,11,21),DATE(2026,8,31),DATE(2026,7,31)) I2: =IF(M2<>"","Done", IF(E2="142(1)","Filed after a 142(1) notice: cannot be revised, talk to the client", IF(D2="",IF(TODAY()<=DATE(2026,12,31),"Belated return u/s 139(4) by 31 Dec","Belated window closed: ITR-U only if tax goes up"), IF(TODAY()<=DATE(2026,12,31),"Revise u/s 139(5) by 31 Dec (no 234-I fee)", IF(TODAY()<=DATE(2027,3,31),"Revise u/s 139(5) by 31 Mar 2027 with 234-I fee","Revision closed: ITR-U only if tax goes up"))))) J2: =IF(OR(M2<>"",E2="142(1)"),0, IF(D2="",IF(H2<=500000,1000,5000), IF(AND(TODAY()>DATE(2026,12,31),TODAY()<=DATE(2027,3,31)),IF(H2<=500000,1000,5000),0))) K2: =TRIM(IF(AND(D2="",G2="Has a loss to carry forward"),"Belated: loss other than house property cannot be carried forward. ","") &IF(G2="Wants old regime","Old regime cannot be chosen after the 139(1) due date. ","") &IF(AND(G2="Deduction or TDS missed (refund goes up)",TODAY()>DATE(2026,12,31)),"Revise by 31 Mar 2027: ITR-U cannot increase a refund. ","") &IF(AND(D2="",H2>0),"Interest u/s 234A on unpaid tax runs until filing. ",""))
Category 2 uses 21 November 2026 because CBDT Circular No. 07/2026 extended the AY 2026-27 due date for audit cases without a section 92E report from 31 October; the other categories use the statutory dates in Explanation 2 to section 139(1) as substituted by the Finance Act, 2026 (category 3 is now 31 August). The 31 December and 31 March dates do not depend on column C, but column C tells you whether a filed return was itself late (D2 > C2): treat a late original like a belated return for the loss and deduction warnings. Sort by I, then J, so every belated row is on top.
Three made-up example rows (not real clients)
| A | B | D | G | H | I result (today) | J |
|---|---|---|---|---|---|---|
| Example Traders (proprietor) | 3 | (blank) | Has a loss to carry forward | 0 | Belated return u/s 139(4) by 31 Dec | 1,000 |
| Sample Salaried Client | 4 | 28 Jul 2026 | Income missed (tax goes up) | 14,60,000 | Revise u/s 139(5) by 31 Dec (no 234-I fee) | 0 |
| Demo Consultant | 3 | 29 Aug 2026 | Deduction or TDS missed (refund goes up) | 9,10,000 | Revise u/s 139(5) by 31 Dec (no 234-I fee) | 0 |
The first row's warning reads "Belated: loss other than house property cannot be carried forward." Tell that client in writing: filing late still matters (it stops the non-filing problem), but the business loss for FY 2025-26 will not carry forward.
What a late return loses (put this in front of the client)
- Losses: a loss other than a house property loss cannot be carried forward from a belated return (return of income page, consequences of delay).
- Some deductions: deductions under Part C of Chapter VI-A are not available in a belated return (same page).
- The old regime: a client without business income can choose the old regime only in a return filed by the section 139(1) due date; the AY 2026-27 ITR-1 validation rules block old-regime selection after that date and in a revised return whose original was belated (CBDT e-filing validation rules, AY 2026-27, rules 151, 189 and 190). A client with business income needed Form 10-IEA by the due date (Form 10-IEA FAQ, Q7 and Q15).
- Money: the section 234F fee, and section 234A interest on any unpaid tax.
Where to find the rows
- Your own AY 2026-27 filing tracker: every client marked "documents pending", "on hold" or "not responding" after their due date.
- Clients who filed but whose AIS/TIS or Form 26AS now shows income, TDS or high-value transactions that are not in the return. Compare before you revise, so you fix everything in one revised return.
- Clients who asked "why is my refund less?" or received a processing intimation that does not match the return.
- Family members and new clients who say "I never filed last year".
Plan to 31 December
| When | What |
|---|---|
| Thu 22 – Sat 31 Oct | Build the clients tab from the four lists above. Send message 1 to every "Not filed" row. |
| Mon 2 – Fri 27 Nov | File belated returns as documents arrive: for these rows the fee is already fixed, but interest on unpaid tax keeps running, so there is nothing to gain by waiting. Your audit-case and transfer pricing work is due 21 and 30 November, so keep belated rows to simple returns this month. |
| Tue 1 – Thu 24 Dec | Revised returns: download AIS/TIS and Form 26AS, list every change, send message 2, file, then get each one e-verified. |
| Mon 28 Dec | Target date for the last belated and revised returns. Thursday 31 December is a buffer only: it is also the FY 2025-26 GSTR-9 date. |
| From Fri 1 Jan 2027 | Belated rows that are still open now switch to "ITR-U only if tax goes up". Revisions are still possible to 31 March 2027, with the section 234-I fee. |
Two client messages
1. Not filed: "Your income-tax return for FY 2025-26 has not been filed. The last date for a late (belated) return is 31 December 2026, with a late fee of ₹1,000 or ₹5,000 depending on your income. After that date the only option is an updated return with extra tax. Please send [documents] by [date] so we can file in November."
2. Correction needed: "While checking your annual information statement we found [item] that is not in your FY 2025-26 return. We can correct it with a revised return free of the new late-revision fee until 31 December 2026; from 1 January 2027 a fee of ₹1,000 or ₹5,000 applies. Please confirm by [date] and send [documents]."
Notes
- Every route ends earlier if the assessment is completed first. Check the e-filing portal for pending proceedings before you promise a client a date.
- From tax year 2026-27, returns move to section 263 of the Income-tax Act, 2025 (belated within 9 months and revised within 12 months from the end of the tax year, per the transition FAQs, Q3.13). This sheet is only for AY 2026-27.
- Section 234-I was inserted by section 16 of the Finance Act, 2026; read its text alongside the department's page before you quote a fee to a client.
- The sheet holds client income data: share it only inside your firm.
Related guides
- December 2026 due-date chase list
- Revised ITR last date for FY 2025-26 (for your clients)
- ITR audit cases: 21 Nov 2026 chase list
- Form 10-IEA sheet (21 Nov 2026)
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