Delayed filing of Form 10CCB is only a procedural lapse and cannot by itself defeat a valid section 80-IB deduction claim.

Deduction under section 80-IB was held not to fail merely because Form 10CCB was uploaded after the due date, where the return was filed within time and the audit report had already been issued before the specified date. The delayed uploading was treated as a procedural lapse that did not affect the assessee's substantive eligibility for the deduction. The Tribunal applied the settled approach that a genuine claim cannot be defeated solely for late filing of supporting evidence when the statutory conditions are otherwise satisfied, and the deduction was directed to be allowed.

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Issues: Whether deduction under section 80-IB could be denied only because Form 10CCB was uploaded after the due date, despite the return being filed within time and the audit report having been issued before the specified date.

Analysis: The assessee had claimed the deduction in the return filed within the extended due date, and the auditor had issued Form 10CCB before the specified date. The only default was delayed uploading of the audit report. The delay was treated as a procedural lapse and not a defect affecting the substantive entitlement to deduction. The Tribunal followed its earlier view and the settled approach that a genuine deduction cannot be denied merely for late filing of supporting evidence when the statutory claim is otherwise available.

Conclusion: Deduction under section 80-IB could not be denied merely for delayed filing of Form 10CCB, and the assessee was entitled to the claim.

Final Conclusion: The deduction was directed to be allowed, with a cost imposed for the lapse in filing, and the appeal succeeded on statistical terms.

Ratio Decidendi: Where the statutory conditions for deduction are otherwise satisfied and the supporting audit report was obtained within time, delayed uploading of Form 10CCB is a curable procedural lapse that cannot by itself defeat the deduction claim.

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