Substantial compliance for Form No. 10 filing upheld where manual submission and prior disclosure cured e-filing technical lapses.

Manual filing of Form No. 10 before the jurisdictional Assessing Officer, combined with prior disclosure of the accumulation amount in the return and allied statements, was treated as substantial compliance with section 11(2) and Rule 17 where electronic upload was prevented by technical difficulties. The position was reinforced by CBDT Circular No. 14(XL-35) and the principle that relief should not be denied for a technical lapse when the relevant information was already before the Department. On that basis, the accumulation claim was allowed.

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Issues: Whether the assessee's claim for accumulation under section 11(2) could be allowed despite the Form No. 10 not being uploaded electronically and having been filed manually before the jurisdictional Assessing Officer within time.

Analysis: The accumulation amount was already reflected in the return of income and allied statements, and the assessee had attempted electronic filing but was prevented by technical difficulties. The manual filing of Form No. 10 before the Assessing Officer was acknowledged. In these circumstances, the requirement under section 11(2) and Rule 17 was treated as having been substantially complied with, supported by the administrative guidance in CBDT Circular No. 14(XL-35) dated 11.04.1955 and the principle that taxpayers should not be denied relief for a technical lapse where the relevant information was already before the Department.

Conclusion: The accumulation claim under section 11(2) was held allowable, and the Revenue's challenge failed.

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