Section 80P deduction cannot be rejected in a section 143(1) intimation solely for late return filing.

A deduction under section 80P could not be denied through an intimation under section 143(1) merely because the return was filed after the due date under section 139(1). The reasoning was that, for the assessment year concerned, the scope of prima facie adjustments under section 143(1) did not extend to disallowing the section 80P claim on that ground, and no specific enabling provision permitted such a mechanical rejection. The adjustment was therefore unsustainable, and the deduction claim was accepted in favour of the assessee.

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Issues: Whether deduction under section 80P of the Income-tax Act, 1961 could be denied through an intimation under section 143(1) solely because the return was filed beyond the due date under section 139(1).

Analysis: The return was admittedly filed belatedly, but the adjustment made under section 143(1) was held unsustainable because the then applicable provision did not provide for disallowance of deduction under section 80P merely on account of late filing. The reasoning turned on the limited scope of prima facie adjustments under section 143(1), which did not include the impugned denial for the assessment year in question. The decision also followed the view that deduction claims of this nature could not be rejected by way of a mechanical adjustment in the absence of a specific enabling provision applicable for that year.

Conclusion: The denial of deduction under section 80P through section 143(1) for delayed filing was not sustainable, and the issue was decided in favour of the assessee.

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