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Issues: (i) whether the assessee was entitled to carry forward the current year business loss despite the return being treated as belated on account of technical difficulties in e-filing; and (ii) whether the claim of tax deducted at source credit as reflected in Form 26AS required verification and consequential credit.
Issue (i): Whether the assessee was entitled to carry forward the current year business loss despite the return being treated as belated on account of technical difficulties in e-filing.
Analysis: The return was filed only minutes beyond the due time because the assessee faced difficulty in registering the digital signature certificate and in completing the filing process on the portal. The record showed contemporaneous grievance communications and supporting screenshots. In these circumstances, the assessee's claim for carry forward of business loss was required to be examined on merits, and the appellate authority could entertain the claim notwithstanding the procedural lapse.
Conclusion: The claim for carry forward of the current year business loss was restored to the Assessing Officer for verification and decision according to law, and the issue was thus decided in favour of the assessee for statistical purposes.
Issue (ii): Whether the claim of tax deducted at source credit as reflected in Form 26AS required verification and consequential credit.
Analysis: The assessee asserted a mismatch between the tax credit claimed in the return and the credit allowed in processing. The matter therefore required factual verification with reference to Form 26AS and the income assessable during the year.
Conclusion: The Assessing Officer was directed to verify the tax credit claim and allow the appropriate credit after verification, resulting in relief to the assessee for statistical purposes.
Final Conclusion: The appeal did not result in an immediate substantive allowance of the claims, but both disputed matters were sent back for verification and reconsideration, with the assessee obtaining statistical relief.
Ratio Decidendi: An appellate authority can entertain a claim for carry forward of loss and direct verification of tax credit where the return-filing delay arose from bona fide technical hardship and the relevant factual issues require examination on merits.
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