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Issues: Whether the assessee was entitled to deduction under section 80IE notwithstanding the belated filing of Form 10CCB, when the audit report was furnished before processing of the return under section 143(1).
Analysis: The return was filed within time and the audit report in Form 10CCB was uploaded before the return was processed under section 143(1). The filing of the audit report was treated as a procedural requirement and not a condition that could extinguish the substantive claim for deduction. Reliance was placed on the principle of sufficient compliance where the prescribed report is filed during the assessment or processing stage before the final order, and on the view that delay in filing the report is a curable procedural lapse.
Conclusion: The disallowance was unsustainable and the assessee was held entitled to the deduction under Chapter VIA.