Return-processing limits on section 80P disallowance: belated filing could not justify adjustment under section 143(1)(a) before the amendment.

A deduction under section 80P could not be disallowed while processing a return under section 143(1)(a) where the return was filed belatedly, because the adjustment did not fall within section 143(1)(a)(ii). The Tribunal further noted that section 143(1)(a)(v) could not be invoked for this purpose before 01.04.2021, when the amendment connecting section 80AC to that clause took effect. The processing adjustment was therefore not sustainable, and the deduction claim could not be denied at the return-processing stage.

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Issues: Whether the disallowance of deduction under section 80P of the Income-tax Act, 1961 could be made while processing the return under section 143(1)(a), in the light of section 80AC and the belated filing of the return.

Analysis: The return for the assessment year was filed beyond the time prescribed under section 139(1). The disallowance was made through processing under section 143(1)(a), relying on section 80AC. The Tribunal noted that the adjustment made in the present case fell outside the scope of section 143(1)(a)(ii), and that the corresponding adjustment under section 143(1)(a)(v) could not be applied before 01.04.2021, when the amendment linking section 80AC to that clause came into force.

Conclusion: The disallowance under section 143(1)(a) was not sustainable, and the claim for deduction under section 80P could not be denied in processing.

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