Late filing of Form 56F does not automatically defeat section 10AA deduction where substantive entitlement remains intact.

A procedural delay in filing Form 56F does not, by itself, defeat a deduction claim under section 10AA where the report is ultimately furnished and the statute contains no express bar to late acceptance. The filing of the accountant's report is a verification requirement, while the deduction remains a substantive exemption-linked benefit. On that basis, the delayed filing was held not fatal to entitlement, and the assessment addition based on non-filing with the return was set aside; the deduction claim was restored in full.

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Issues: Whether deduction under section 10AA of the Income-tax Act, 1961 could be denied solely because Form 56F was not filed along with the return of income within the prescribed time.

Analysis: The deduction under section 10AA is a substantive exemption-linked benefit, while the filing of the accountant's report in Form 56F serves to verify the claim. The order accepted that the form was filed later, and the question was whether delayed filing extinguished the claim. Following the view that no express statutory bar prevents acceptance of the report after the due date, and treating the delay as not fatal to the substantive entitlement, the procedural lapse was held insufficient to defeat the deduction.

Conclusion: The delayed filing of Form 56F did not justify denial of deduction under section 10AA, and the assessee was entitled to the claimed deduction.

Final Conclusion: The assessment addition based on non-filing of Form 56F with the return was set aside and the deduction claim was restored in full.

Ratio Decidendi: A procedural delay in furnishing the prescribed audit report does not defeat a substantive deduction claim under section 10AA where the statute does not create an express bar and the report is otherwise furnished.

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