Strict compliance with return filing due date required for section 80IC deduction; late filing defeats the claim.

Section 80IC deduction was treated as unavailable where the return of income was not furnished within the due date under section 139(1). The Tribunal applied strict construction to exemption and deduction provisions and held section 80AC to be clear and mandatory, so the statutory filing condition had to be satisfied exactly as written. Because the return was late, the precondition for claiming the deduction was not met and the disallowance was sustained.

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Issues: Whether deduction under section 80IC was admissible when the return of income was not furnished within the due date under section 139(1), and whether compliance with section 80AC was mandatory for the claim.

Analysis: The provision in section 80AC was held to be clear and unambiguous. The Tribunal applied the principle that exemption and deduction provisions must be construed strictly, and that where the language of the statute admits of no ambiguity, the condition prescribed by the legislature has to be satisfied as written. In view of the constitutional bench ruling on strict construction of exemption provisions, the earlier contrary line of authority was treated as no longer assisting the assessee. Since the return was not filed within the time prescribed under section 139(1), the statutory precondition for availing deduction under section 80IC was not met.

Conclusion: The deduction under section 80IC was not allowable, and the disallowance was sustained.

Ratio Decidendi: A deduction governed by section 80AC is available only if the return of income is furnished on or before the due date under section 139(1); failure to satisfy that mandatory condition disentitles the assessee from the deduction.

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