Delayed verification of e-filed return does not bar Chapter VI-A deductions; 80P deduction remains allowable.

Delayed completion of verification of an electronically filed return is a procedural lapse that does not defeat substantive entitlement to a Chapter VI-A deduction where the electronic return was furnished within the due date under section 139(1); Notification No. 5/2022 treating verification-date as filing-date does not override the curability of verification delay for denial under section 80AC, and therefore the deduction under section 80P is to be allowed. The analysis treats verification as procedural validation and sets aside disallowance based solely on post-30-day verification.

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Issues: Whether deduction claimed under section 80P of the Income-tax Act, 1961 can be denied on the ground that verification of an electronically filed return was completed after 30 days, causing the return to be treated as belated.

Analysis: The return was electronically filed within the due date prescribed by section 139(1) of the Income-tax Act, 1961, but verification was completed after the 30-day period. Notification No. 5/2022 of the Central Board of Direct Taxes provides that where verification is not completed within 30 days the return may be treated as filed on the date of verification; section 80AC of the Income-tax Act, 1961 disallows certain chapter VI-A deductions if the return is not furnished within the due date under section 139(1). The issue requires assessment of whether delayed completion of the procedural step of verification, subsequently cured, defeats substantive entitlement to deduction under section 80P. The analysis considers the nature of verification as a procedural validation of an already filed return and reviews precedent treating delayed verification as a curable procedural lapse where the substantive filing occurred within the due date.

Conclusion: The deduction under section 80P of the Income-tax Act, 1961 cannot be denied solely on account of delayed verification of an electronically filed return when the return was furnished within the due date under section 139(1); the disallowance is set aside and the deduction is to be allowed.

Ratio Decidendi: A procedural lapse in completing verification of an electronically filed return that is subsequently cured does not convert a timely filed return into a belated return for the purpose of denying chapter VI-A deductions under section 80AC when the original electronic filing was within the section 139(1) due date.

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