2022 (11) TMI 423 - AT - Income Tax

Tribunal denies deduction under section 80IC for late e-filing, emphasizes timely compliance -filing

The Tribunal affirmed the disallowance of the deduction under section 80IC for the assessment year 2012-13 due to the assessee's failure to e-file the ... Deduction u/s 80IC - assessee company has failed to e-file the return of income or manual filing within the due date specified as per section 139(1) - HELD THAT:- By following the decision of the Tribunal in assessee’s own case for the assessment year 2011-12 [2014 (8) TMI 674 - ITAT CHENNAI] AO has made disallowance of deduction claimed under section 80IC which was rightly confirmed by the ld. CIT(A). Thus, we find no infirmity in the order passed by the ld. CIT(A). Accordingly, the ground raised by the assessee is dismissed. Issues:Claim of deduction under section 80IC of the Income Tax Act for assessment year 2012-13 based on e-filing of return of income after the due date specified in section 139(1) of the Act.Analysis:The appeal was against the order of the Commissioner of Income Tax (Appeals) regarding the disallowance of a deduction under section 80IC of the Act for the assessment year 2012-13. The assessee, engaged in manufacturing medicines, e-filed its return after the due date, leading to the disallowance. The Assessing Officer noted that failure to e-file within the due date specified in section 139(1) rendered the assessee ineligible for the deduction under section 80IC. Referring to a previous year's decision, it was held that repeating the mistake of late e-filing was unacceptable. The Tribunal upheld the disallowance based on the assessee's failure to comply with the e-filing requirement for claiming the deduction.The Tribunal cited a previous decision for the assessment year 2011-12 where the assessee's claim for deduction under section 80IC was rejected due to late e-filing without a valid reason. The Tribunal emphasized that ignorance of the tax consultant was not a valid excuse for late filing. The Tribunal also distinguished cases where delays were due to supervening impossibility, granting extensions in those instances. The Tribunal highlighted the mandatory e-filing requirement for certain assessment years and how failure to comply rendered the assessee ineligible for the deduction.The Tribunal dismissed the assessee's appeal, affirming the disallowance of the deduction under section 80IC for the assessment year 2012-13. The decision was based on the assessee's failure to e-file the return within the specified due date, following a precedent set in a previous year's case. The Tribunal emphasized the importance of timely compliance with e-filing requirements for claiming deductions under the Income Tax Act. The appeal was dismissed, upholding the orders of the authorities below and confirming the disallowance of the deduction under section 80IC for the assessment year 2012-13.In conclusion, the Tribunal upheld the disallowance of the deduction under section 80IC for the assessment year 2012-13 due to the assessee's failure to e-file the return within the specified due date. The decision was consistent with a previous ruling regarding the importance of timely compliance with e-filing requirements for claiming deductions under the Income Tax Act. The Tribunal dismissed the appeal, affirming the orders of the lower authorities and maintaining the disallowance of the deduction for the said assessment year.