Deduction under Section 80JJAA upheld where Form 10DA filed with revised return within extended due date before processing.

Deduction under Section 80JJAA was upheld where the mandatory audit report in Form 10DA, though omitted from the original return, was filed with the revised return within the extended statutory due date and made available before processing; the Tribunal treated the omission as a procedural defect curable by timely filing, applied the due-date requirement and principles of compliance at processing stage, and remitted the matter to the Assessing Officer for limited verification and quantification of the allowable deduction.

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Issues: Whether deduction under Section 80JJAA of the Income-tax Act, 1961 can be allowed where the mandatory audit report in Form 10DA was not filed with the original return but was filed with the revised return within the extended due date and prior to processing under Section 143(1).

Analysis: The Tribunal examined whether non-filing of the mandatory Form 10DA with the original return is a procedural omission that can be cured by filing the form with the revised return within the extended statutory time and before processing under Section 143(1). The analysis applies Section 80JJAA read with the due date requirement in Section 139(1) and considers authorities establishing that mandatory forms filed before finality of assessment or before processing may constitute sufficient compliance. The Tribunal noted that the return and the revised return (with Form 10DA) were filed within CBDT-extended timelines and that the Form 10DA was available to the CPC at the time of processing, and therefore the procedural lapse did not defeat the substantive entitlement to deduction.

Conclusion: The procedural omission of not filing Form 10DA with the original return does not bar allowance of deduction under Section 80JJAA where the report is filed with the revised return within the extended due dates and is available before processing; matter remitted to Assessing Officer for limited verification and quantification of allowable deduction.

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