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Issues: Whether the denial of exemption under section 11 of the Income-tax Act, 1961 on the ground of belated filing of Audit Report in Form 10B (acknowledgement generated after the statutory due date due to technical glitches) was justified.
Analysis: Relevant statutory provisions include Section 11 (exemption for charitable purposes) and the filing requirement under Section 12A(1)(b) read with the due date for return under Section 139(1). The assessee availed the extended timeline notified by the competent authority and electronically uploaded Form 10B on 14-02-2022, within the extended timeline, while the system-generated acknowledgement was produced on 25-02-2022 due to technical issues. The assessing authority issued a rectification under Section 154, treating the late system acknowledgement as delayed filing and denying exemption. A coordinate bench of the Tribunal has addressed identical facts and allowed exemption where electronic upload occurred within the prescribed period but system acknowledgement was delayed due to technical glitches. Applying that reasoning to the present facts, the uploading within the extended time and supporting electronic metadata establishes compliance with the filing requirement and defeats the basis for denial under the rectification order.
Conclusion: Exemption under Section 11 of the Income-tax Act, 1961 is allowed; the Revenue's appeal is dismissed and the rectification denial of exemption is set aside in favour of the assessee.
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