Electronic filing of Form 56F not required for section 10AA claim where physical filing was completed before assessment.

Deduction under section 10AA could not be denied solely because Form 56F was not furnished electronically with the return, where the report had been filed in physical form before completion of assessment. The Tribunal read Rule 12(2) as making electronic filing applicable to section 10AA only from 1 April 2014, so it did not govern assessment year 2013-14. On that basis, physical filing before assessment was treated as sufficient compliance, and denial of the deduction on the electronic-filing requirement alone was unsustainable.

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Issues: Whether deduction under section 10AA could be denied for failure to furnish Form 56F electronically along with the return when the report had been filed in physical form before completion of assessment.

Analysis: The appeal turned on the effect of Rule 12(2) of the Income-tax Rules, 1962, which required electronic furnishing of the report. The Tribunal held that the electronic filing requirement, as applied to section 10AA, was effective only from 01.04.2014 and therefore did not govern the assessment year 2013-14. It further held that filing the report in physical form before the assessment was completed amounted to compliance, and the absence of electronic filing alone could not justify denial of the deduction.

Conclusion: The disallowance of deduction under section 10AA was unsustainable and was deleted in favour of the assessee.

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