Section 11 exemption cannot be denied solely for delayed Form 10B upload, with merits requiring fresh examination.

Exemption under section 11 could not be denied solely because Form 10B was uploaded belatedly where the return was filed within the extended due date and the form had been uploaded with the return and during processing. Relying on precedent, the Tribunal treated the filing lapse as insufficient by itself to refuse exemption. It also found that the lower appellate authority should not have finally rejected relief without examining the claim on merits, especially when condonation had already been sought before the competent authority under section 119(2)(b). The matter was therefore remitted for fresh adjudication on merits.

---

---

Issues: Whether exemption under section 11 could be denied solely because Form 10B was uploaded belatedly, and whether the matter required fresh examination on merits.

Analysis: The Tribunal noted that the return was filed within the extended due date and that Form 10B had been uploaded along with the return and during processing. In these circumstances, and following the relied upon precedent, the Tribunal treated the filing requirement as not warranting denial of exemption on the sole ground of delay. The Tribunal also held that the lower appellate authority should not have finally declined relief without examining the claim on merits, particularly when the assessee had already pursued condonation before the competent authority under section 119(2)(b).

Conclusion: Denial of exemption only for delayed upload of Form 10B was not sustained, and the matter was sent back for fresh adjudication on merits.

---