Deemed application claim: timely manual Form No. 10 filing may cure later electronic filing lapse under section 11(2).

Form No. 10 filed manually before the due date was treated as a timely claim for deemed application of income under section 11(2), and the later electronic filing during assessment was relevant to the record. Because the electronic filing requirement had come into force from 01.04.2016, the failure to e-file within time was regarded as a curable procedural lapse rather than a ground to reject the claim outright. The matter was restored for fresh consideration of the manual filing and the subsequent electronic filing in accordance with law.

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Issues: Whether the assessee was entitled to claim deemed application of income under section 11(2) despite Form No. 10 having been filed manually within time but not electronically before the due date, and whether the matter required reconsideration.

Analysis: The assessee had filed Form No. 10 manually before the due date of return, and the electronic filing requirement had come into force from 01.04.2016. The subsequent electronic filing during assessment proceedings was also on record. In these circumstances, the failure to e-file the form within time was treated as a curable procedural lapse, and the claim could not be rejected merely on that ground without examining the timely manual filing.

Conclusion: The issue was restored to the Assessing Officer for fresh consideration of the manual filing and the later electronic filing in accordance with law.

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