Mandatory accountant certification for section 10A deduction required valid Form 56F filing and denied relief when certification was defective.

Deduction under section 10A was denied because compliance with the prescribed accountant's report requirement was mandatory. Form 56F had been filed with the return, but it was not shown to be duly certified by an accountant as defined under the Income-tax Act, and the assessee produced no material proving that the signing firm satisfied that statutory definition. The defective certification meant the statutory precondition for the deduction was not met, so the claim was not admissible.

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Issues: Whether deduction under section 10A of the Income-tax Act, 1961 could be allowed when the prescribed Form 56F was treated as defective for want of proper certification by an accountant.

Analysis: The deduction under section 10A is subject to the statutory condition that the assessee furnishes the prescribed report of an accountant along with the return of income before the specified date. The report must be certified by an accountant within the meaning of the Explanation to section 288(2) of the Income-tax Act, 1961. On the record, the assessee did file Form 56F with the return, but the form was not shown to have been duly certified by a qualified accountant as required by law. The assessee also failed to produce material establishing that the firm signing the form satisfied the statutory definition of accountant.

Conclusion: The deduction under section 10A was not admissible. The assessee did not satisfy the mandatory certification requirement, and the defect in Form 56F justified denial of the claim.

Ratio Decidendi: Where a tax deduction is made conditional on furnishing a prescribed accountant's report, compliance is mandatory and the report must be certified by a person who satisfies the statutory definition of accountant; absence of such valid certification disentitles the assessee to the deduction.

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