Substantive compliance for section 80JJA deduction prevails when Form 10DA is uploaded in time despite delayed verification.

A deduction under section 80JJA should not be denied merely because Form 10DA was digitally verified after the due date, where the audit report had already been uploaded in time and was available before processing of the return. The Tribunal treated late verification as a procedural lapse, not a failure of the substantive statutory requirement, and held that technical delay should not override an otherwise timely and complete claim. On that basis, the disallowance was found unjustified and the deduction was allowed, reflecting the principle that substantive compliance prevails where the statutory purpose has been satisfied.

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Issues: Whether the deduction under section 80JJA of the Income-tax Act, 1961 could be disallowed merely because Form 10DA was verified after the due date, when the form had been uploaded before the due date and was available before the processing of the return.

Analysis: The deduction claim was supported by an audit report uploaded before the due date, and the later digital verification was treated as a procedural lapse rather than a failure of the substantive requirement. The Tribunal distinguished the authorities relied upon by the Revenue and preferred the principle that where the statutory condition is substantially met and the prescribed report is available before the claim is finally processed, a technical delay in verification should not defeat the deduction. The Tribunal also relied on the view that procedural compliance should not override the substantive entitlement when the underlying report is filed in time and the statutory purpose is satisfied.

Conclusion: The disallowance of deduction under section 80JJA was unjustified, and the claim was allowed in favour of the assessee.

Ratio Decidendi: Where a prescribed report supporting a deduction is uploaded within time and is available before the return is processed, a delayed verification alone does not justify denial of the deduction if the statutory requirement is otherwise substantially complied with.

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