Procedural lapse in filing audit report cannot defeat statutory deduction where return was timely and eligibility was established.

Delayed uploading of Form No. 10CCB and an incorrect sub-head selection in the return were treated as procedural lapses, not grounds to deny deduction under section 80-IA(4)(iv), where the return was filed within time and the claim was made in the return itself. Because the audit certificate had been prepared before the due date and the delay was explained by affidavit, the defect did not affect the assessee's substantive eligibility. The deduction was therefore allowed on the basis that a technical error should not defeat a statutory claim when the underlying entitlement is established.

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Issues: Whether deduction under section 80-IA(4)(iv) could be denied for delayed uploading of Form No. 10CCB and an inadvertent wrong selection of the sub-head in the return when the assessee had filed the return within time and the audit certificate had been prepared within time.

Analysis: The return was filed before the due date and the claim for deduction under section 80-IA was made in the return itself. Form No. 10CCB had been prepared before the specified date, and the delay in uploading was explained by affidavit. The wrong selection of the sub-head in the schedule was treated as an inadvertent human error. On these facts, the delay in filing the certificate was held to be a procedural lapse and not a reason to deny a deduction otherwise statutorily available. The reasoning was supported by the view that technical defects should not defeat a substantive claim where the underlying eligibility is not in doubt.

Conclusion: The deduction under section 80-IA(4)(iv) could not be denied on the ground of delayed filing of Form No. 10CCB or the incorrect sub-head selection, and the assessee was entitled to the deduction.

Ratio Decidendi: A procedural defect in filing the supporting audit report cannot defeat a statutory deduction when eligibility is established and the default is explained, especially where the claim was made in the return filed within time.

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