The Gujarat High Court held that after the amendment by the Finance Act, 2020, the “specified date” for furnishing the tax audit report under Expln. (ii) to s. 44AB is statutorily fixed as one month prior to the “due date” for filing the return under s. 139(1). Therefore, once CBDT, by Circular No. 14 of 2025, extended the specified date from 30-09-2025 to 31-10-2025, it was incumbent upon it to correspondingly extend the due date for filing the return from 31-10-2025 to 30-11-2025. Merely extending the specified date without extending the due date would render Expln. (ii) to s. 44AB otiose and defeat the legislative intent behind the 2020 amendment, effectively restoring the pre-amendment position of simultaneous filing of audit report and return. Rejecting CBDT’s stand that it would monitor the e-filing portal and decide later, the Court held that such an approach was contrary to the statutory scheme. Accordingly, the Court directed CBDT to issue a consequential circular under s. 119 extending the due date for filing returns up to 30-11-2025 for assessees required to furnish audit reports for FY 2024-25 relevant to AY 2025-26.(AY. 20025-26)