Quick Summary
A circular has been issued on 30 December 2025 that it has extended the due date for ROC annual filings pertaining to FY 2024-25 from 31 December 2025 to 31 January 2026, providing significant relief due to high late fees.
It means
No late fee applies until 31 January 2026, allowing filers to prioritize other tasks without penalty for ROC up to the new deadline.
Strategic Shift to GSTR-9 and GSTR-9C Filings
With the extension of ROC, the focus immediately shifts to GSTR-9 (annual return) and GSTR-9C (reconciliation statement), as no extension applies to them and late fees begin accruing from 1 January 2026 at ₹200 per day.
Similarly, no extension for ITR-revised or belated ITR for audit cases ends 31 December 2025.
Recommended Filing Priority Order
- Top Priority: File both GSTR-9 & GSTR-9C by 31st December 2025 as late fees of ₹200/day start 1 January 2026. Do GSTR-9 first; GSTR-9C adds fees only for extra delay days after.
- Next: Finish Revised/Belated ITRs by 31 Dec for refunds or notice responses. After 31 Dec, only "updated returns" will be allowed with additional tax of 25% (if filed within 12 months), 50% (within 24 months), 60% (within 36 months) and 70% (within 48 months).
- Last: ROC AOC-4 & MGT-7 -relax until 31 Jan 2026 with no late fees.
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