The audit report is due tomorrow. There is no third date
21 October is the extended date, not a first draft of one. This issue is dated Tuesday rather than Sunday because a paper that reached you after the date would have been of no use at all.
One day left, and nothing further is coming. The CBDT moved the specified date once, by Circular 07/2026 of 28 September, from 30 September to 21 October 2026, and has notified nothing since. Three weeks were added for a filing season, not as the first instalment of a longer reprieve, and the department has given no indication of a second move. If the report under section 44AB is not filed by tomorrow, section 271B measures from the 21st: 0.5% of turnover or ₹1,50,000, whichever is lower.
Two dates did not move with it, and this is where the week's mistakes will be made. Where section 92E applies anywhere in a group — any international transaction, or a specified domestic one — the accountant's report in Form 3CEB stays due 31 October and that return 30 November. The September circular covered the entry at Serial No. 2 of the table under section 139(1); it did not touch the transfer-pricing entry. A group that read "extended" and relaxed has eleven days on its harder deadline, not thirty-two.
If the report will not be signed by tomorrow, the decision to make today is which of two positions you are in. A report filed late is a default under 271B and the penalty is computed from the 21st; a report not filed at all leaves the return itself exposed. Section 273B relieves the penalty where there was reasonable cause, and reasonable cause is a record, not an argument — the auditor's written position on why the date could not be met, dated now rather than reconstructed when a notice arrives. A file opened today is worth more than a better explanation offered in March.