SSI registration certificate not mandatory for section 80IA deduction where unit was otherwise regarded as a small-scale industrial undertaking.

Deduction under section 80IA could not be denied merely for non-production of the final SSI registration certificate where the undertaking was otherwise regarded as a small-scale industrial undertaking under section 11B of the Industries (Development and Regulation) Act, 1951. The provision turns on whether the industrial undertaking is "regarded" as an SSI unit on the last day of the previous year, not on formal "registration". Since the unit had been treated as an SSI unit by the competent authorities, the missing certificate was only a technical defect, and formal SSI registration was not a statutory precondition for the deduction.

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Issues: Whether deduction under section 80IA of the Income-tax Act, 1961 could be denied merely because the assessee did not produce a final SSI registration certificate, when the undertaking was otherwise regarded as a small-scale industrial undertaking under section 11B of the Industries (Development and Regulation) Act, 1951.

Analysis: The relevant definition in section 80IA looks to whether the industrial undertaking is, as on the last day of the previous year, regarded as a small-scale industrial undertaking under section 11B of the Industries (Development and Regulation) Act, 1951. The decisive statutory expression is "regarded" and not "registered". On the facts, the undertaking had been treated as an SSI unit by the competent authorities, and the absence of a final registration certificate was only a technical deficiency. Prior decisions on similar facts were followed to hold that formal SSI registration is not a statutory precondition for the deduction.

Conclusion: The deduction under section 80IA could not be refused on the sole ground of non-production of the final SSI registration certificate, and the claim was allowable.

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