A S BANKA ADVISORS

Two Deadlines, One Date, Zero Extensions

March 31, 2026 marks the convergence of two critical regulatory deadlines that affect millions of Indian directors and tax deductors. Missing either one creates permanent compliance gaps with no future remedy.

The Ministry of Corporate Affairs (MCA) is overhauling director KYC requirements, while the repeal of the Income Tax Act, 1961 permanently closes the TDS/TCS correction window. Here is what you need to know and what you must do in the next 13 days.

Deadline 1: MCA Director KYC Shifts to Triennial Filing

MCA Notification G.S.R. 943(E) dated December 31, 2025 amends Rule 12A of the Companies (Appointment and Qualification of Directors) Rules, 2014. The key change: director KYC filing moves from an annual cycle to a triennial (every three years) cycle, effective March 31, 2026.

What Changed Under the New Rule

• Filing frequency: Triennial instead of annual
• Form: DIR-3-KYC-Web (unchanged)
• Routine filing deadline: June 30 of the applicable year
• Digital signature: Not required for routine triennial filings
• Professional certification: Only required for event-based changes (address/contact updates within 30 days)

Critical March 31 Action: DIN Reactivation

If any of your directors have a deactivated DIN, it can only be reactivated under the old framework until March 31, 2026. After this date, the old reactivation process becomes permanently unavailable. This affects approximately 3 million directors across India.

Triennial Transition Schedule

• Filed KYC for FY 2024-25: Next filing due June 30, 2028
• Filed KYC for FY 2025-26: Next filing due June 30, 2029
• DIN allotted after April 1, 2025: Next filing due June 30, 2029
• Address/contact change: Within 30 days of the change (with digital signature and CA/CS certification)

Deadline 2: TDS/TCS Correction Window Closes Permanently

The Income Tax Act, 1961 stands repealed effective April 1, 2026 under Section 536 of the new Income Tax Act, 2025. This means the TRACES portal (tdscpc.gov.in) will permanently reject all correction statements after March 31, 2026 for the following periods:

• FY 2018-19 (Q4 only)
• FY 2019-20 through FY 2022-23 (all quarters)
• FY 2023-24 (Q1 through Q3 only)

Under the new Income Tax Act, 2025, the TDS/TCS correction window shrinks from six years to just two years. Any PAN mismatch, incorrect deduction amount, or wrong section code entry left uncorrected becomes a permanent, uncorrectable demand.

Consequences of Missing This Deadline

• Outstanding tax demands become permanent with no remedy
• Deductee refunds get denied due to Form 26AS/AIS discrepancies
• Interest and penalties continue accruing indefinitely
• No legal recourse available after April 1, 2026

Your 13-Day Action Plan

March 18-20 (Audit): Pull DIN status from MCA portal for all directors. Download TDS/TCS statements from TRACES for FY 2018-19 to FY 2023-24.

March 21-24 (Prepare): Compile PAN mismatch lists, gather DIN reactivation documents, prepare DIR-3-KYC-Web forms.

March 25-28 (File): Submit DIN reactivation applications. File TDS/TCS correction statements on TRACES. Submit pending DIR-3-KYC-Web forms.

March 29-31 (Verify): Confirm DIN reactivation on MCA portal. Verify corrected Form 26AS reflects updated entries.

Download the full compliance carousel PDF for your records

Need Help Navigating These Dual Deadlines?

A S Banka Advisors Private Limited offers director KYC filing assistance, DIN reactivation support, and TDS/TCS reconciliation services with deadline-focused advisory.

Book a quick call with our team

Source: Tax Update India | MCA Notification G.S.R. 943(E), December 31, 2025 | Income Tax Act 2025, Section 536

Disclaimer: This article is for informational purposes only and does not constitute legal or tax advice. Consult a qualified professional for specific guidance.