Delayed Form 10B filing does not by itself bar section 11 exemption; merits-based verification remains necessary.

Delay in filing Form 10B under section 139 was treated as directory, not mandatory, so exemption under section 11 could not be denied solely on that basis. The disallowance was therefore not sustained merely because the form was filed after the prescribed date, and the claim required examination on merits. The matter was restored for fresh factual verification and adjudication of the exemption claim.

---

---

Issues: Whether exemption under section 11 could be denied merely because Form 10B was filed after the due date prescribed under section 139, and whether the matter required remand for fresh verification.

Analysis: The filing of Form 10B within the prescribed date was treated as directory and not mandatory. In view of the existing judicial position, the disallowance based solely on delayed filing could not be sustained without further factual examination of the claim on merits.

Conclusion: The denial of exemption was not upheld on this ground, and the matter was restored for fresh factual verification and adjudication on merits.

Ratio Decidendi: Delay in filing Form 10B, by itself, does not justify denial of section 11 exemption where the requirement is directory and the claim otherwise calls for merits-based verification.

---