Section 80IA deduction cannot be denied for delayed Form 10CCB filing when the audit report is submitted before processing.

Deduction under Section 80IA could not be denied merely because Form 10CCB was uploaded after the return due date, where the return was filed on time and the audit report was available before the CPC issued the intimation under Section 143(1). The filing requirement was treated as procedural and directory rather than mandatory, and the assessee was held to have substantially complied with it. On that basis, the adjustment in the intimation was unsustainable and the deduction was allowed.

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Issues: Whether deduction under Section 80IA could be denied merely because Form 10CCB was filed after the due date for filing the return, when the report was filed before the intimation under Section 143(1) was issued.

Analysis: The return was filed within time, while Form 10CCB was uploaded later but before the CPC passed the intimation. The statutory condition relating to filing of the audit report was treated as procedural and directory rather than mandatory, and the assessee was found to have substantially complied with the requirement. Since the report was available before the impugned adjustment was made, the denial of deduction was unsustainable.

Conclusion: The assessee was entitled to deduction under Section 80IA and the adjustment made in the intimation under Section 143(1) was liable to be deleted.

Final Conclusion: The Revenue's challenge failed and the relief granted to the assessee was sustained.

Ratio Decidendi: Filing of Form 10CCB before completion of the relevant processing or assessment is sufficient compliance where the requirement is procedural and directory, and deduction under Section 80IA cannot be denied solely for delayed filing of the audit report.

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