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Issues: Whether deduction under section 80P of the Income-tax Act, 1961 could be denied on the ground that the return was filed beyond the original due date, when the due date had been extended by CBDT circular.
Analysis: The assessee's claim was rejected below only because the return was treated as not filed within section 139(1). The Tribunal noted that CBDT, by order under section 119, had extended the due date for the relevant assessment year to 31.10.2018. Since the return had been filed on 30.10.2018, it was within the extended time limit. In that situation, the disallowance based on section 80AC could not survive, and the only statutory consequence for filing within the extended time was the liability to interest under section 234A, as stated in the circular.
Conclusion: The denial of deduction under section 80P was unsustainable, and the deduction was directed to be allowed in favour of the assessee.