Section 80C deduction for an inadvertent omission in the return was allowed where the pre-01.04.2018 bar did not apply.

Deduction under section 80C remained available where the assessee had furnished the return of income but had inadvertently omitted to claim the deduction in that return. The pre-01.04.2018 position governed the assessment year, so the bar in section 80AC did not apply, and the statutory requirement of filing the return was satisfied. A genuine omission, supported by the CBDT's liberal approach to such claims, did not by itself defeat the deduction. The disallowance was therefore set aside and the claimed deduction was allowed in reassessment.

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Issues: Whether deduction under section 80C of the Income-tax Act, 1961 could be allowed when the assessee had omitted to claim it in the return filed for the relevant assessment year.

Analysis: The return of income had been furnished, and the omission to claim the deduction was held to be inadvertent. The bar under section 80AC, which restricts deductions in the specified chapter, was noted to operate only from 01.04.2018, and was not applicable to the assessment year in question. Since the statutory requirement of furnishing the return stood satisfied, the claim under section 80C was held to be allowable. The assessee's reliance on the CBDT circular supporting a liberal approach to genuine omission was also accepted as consistent with the relief claimed.

Conclusion: The deduction under section 80C was allowed in favour of the assessee.

Final Conclusion: The disallowance was set aside and the assessee obtained the claimed deduction in reassessment.

Ratio Decidendi: For an assessment year to which the pre-01.04.2018 regime applied, omission to expressly claim a deduction in the return does not, by itself, disentitle an assessee from the deduction where the return has been furnished and the statutory bar in section 80AC is inapplicable.

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