Belated deduction claim under Section 80IB survives where merits, past allowances, and documents support the claim.

A belated claim for deduction under Section 80IB, read with Section 80AC and Section 139(1), was examined on merits by the Assessing Officer and the appellate authorities. The record showed that the deduction had been allowed in earlier assessment years and that supporting documents were furnished. On that basis, the Revenue's objection regarding alleged non-receipt of intimation under Section 143(1) was treated as irrelevant, and the concurrent factual and legal findings were held not to raise any substantial question of law. The deduction claim was therefore not disturbed and the Revenue's challenge failed.

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Issues: Whether the assessee's claim for deduction under Section 80IB of the Income-tax Act, 1961, made in a belated return, was barred by Section 80AC read with Section 139(1) of the Income-tax Act, 1961, so as to give rise to a substantial question of law.

Analysis: The deduction claim had been examined by the Assessing Officer and the appellate authorities on merits. The record also showed that the deduction had been allowed in earlier assessment years and that the necessary supporting documents were furnished. In these circumstances, the Court held that the Revenue's grievance about the alleged non-receipt of intimation under Section 143(1) was of no consequence and that the concurrent factual and legal appreciation by the lower authorities did not disclose any substantial question of law.

Conclusion: The issue was decided against the Revenue and in favour of the assessee; the belated deduction claim was not interfered with, and the appeal failed.

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