Deduction under Section 80IB(11A) upheld where Form 10CCB was furnished before assessment finalisation, directing allowance.

Belated filing of the audit certificate in Form No.10CCB does not defeat a claim for deduction under Section 80IB(11A) where the certificate was placed on record before completion or finalisation of assessment; the Tribunal held that for Chapter VIA deductions statutory compliance is satisfied if the requisite audit report is available to the assessing authority prior to final order, distinguishing exemption jurisprudence as inapplicable, and directed allowance of the deduction after setting aside the disallowance.

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Issues: (i) Whether deduction under Section 80IB(11A) of the Income-tax Act, 1961 can be denied solely on account of belated filing of Form No.10CCB when the audit report was furnished before processing of the return under Section 143(1).

Analysis: The issue concerns entitlement to deduction under Section 80IB(11A) where the audit report in Form No.10CCB was not filed with the return but was furnished in response to CPC communication and was on record before the processing/issuance of intimation under Section 143(1). The Tribunal examined precedents distinguishing exemption provisions from deduction provisions and applied coordinate-bench authorities holding that, for deduction claims under Chapter VIA, filing the requisite audit certificate before the final order of assessment suffices. The Tribunal found the cited exemption-related decisions inapplicable and followed recent coordinate-bench decisions which allowed deduction where Form No.10CCB was available to the assessing authority prior to finalisation of assessment.

Conclusion: Deduction under Section 80IB(11A) is allowable where the audit report in Form No.10CCB was furnished before processing of the return under Section 143(1); the disallowance is set aside and the deduction is directed to be allowed in favour of the assessee.

Ratio Decidendi: For claims of deduction under Chapter VIA, a required audit certificate filed prior to the completion or finalisation of assessment proceedings satisfies the statutory compliance and entitles the assessee to the deduction despite not being filed with the original return.

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