Prima facie adjustment limits bar denial of section 80P deduction for a marginally delayed e-filed return.

Deduction under section 80P could not be denied as a prima facie adjustment in processing under section 143(1) for Assessment Year 2019-20, because the disallowance power in section 143(1)(a)(v) applied only from 01.04.2021. Although section 80AC requires the return to be filed by the due date under section 139(1), the return here was uploaded with only a marginal delay attributed to e-filing difficulty, and the processing adjustment exceeded the then-applicable scope. The adjustment and resulting demand were therefore quashed in favour of the assessee.

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Issues: Whether the deduction under section 80P could be denied in processing under section 143(1) merely because the return, uploaded a few minutes after midnight, was treated as a belated return for the relevant assessment year.

Analysis: The applicable legal framework was section 80AC, which bars the deduction unless the return is furnished on or before the due date under section 139(1), and section 143(1)(a)(v), which permits disallowance of Chapter VI-A deductions only from the amendment effective 01.04.2021. For Assessment Year 2019-20, that disallowance power under section 143(1)(a)(v) was not yet available. The return was uploaded with only a marginal delay attributed to technical difficulty in the e-filing process, and the denial of deduction was made as a prima facie adjustment beyond the then-applicable scope of processing.

Conclusion: The denial of deduction under section 80P in processing under section 143(1) was unsustainable for Assessment Year 2019-20, and the adjustment and resulting demand were quashed in favour of the assessee.

Ratio Decidendi: A deduction claim that is otherwise barred only by a belated return cannot be disallowed as a prima facie adjustment under section 143(1)(a)(v) for an assessment year to which that amendment does not apply.

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