Timely Form 10B filing preserves charitable trust exemption; adjustment for alleged belated filing under section 143(1)(a) fails.

Form 10B audit report was treated as timely filed where the record showed uploading on 25.09.2022 within the extended deadline, so the charitable trust exemption could not be denied on belated-filing grounds. The Revenue's contention that filing occurred on 12.10.2022 was rejected in light of the portal record and the assessee's categorical submission. As the filing requirement under section 12A(1)(b) was satisfied, the adjustment under section 143(1)(a) for alleged non-compliance was unsustainable, and the claimed exemption remained available.

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Issues: Whether the assessee trust's Form 10B audit report was filed within the prescribed time so as to preserve exemption under the charitable trust provisions and whether the adjustment made under section 143(1)(a) on the ground of belated filing was sustainable.

Analysis: The audit report was found to have been uploaded on 25.09.2022, within the relevant extended deadline. The Revenue's plea that it was filed on 12.10.2022 was not accepted in view of the documentary record and the categorical submission that the report had been uploaded on the portal within time. The adjustment proposed on the footing of non-compliance with the filing requirement under section 12A(1)(b) was therefore not justified.

Conclusion: The Form 10B audit report was held to be timely filed, the assessee remained entitled to the claimed exemption, and the Revenue's appeal failed.

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