Delayed filing of audit report does not defeat section 80IC deduction when substantive conditions are met and report was on record.

Deduction under section 80IC was not denied merely because Form 10CCB was uploaded after the due date, where the audit report had been obtained in time and was on record before processing under section 143(1). The requirement to file the report along with the return was treated as directory, so delayed electronic filing did not defeat the substantive claim. On that basis, rejection of rectification was unsustainable and the deduction remained allowable despite the belated upload.

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Issues: Whether deduction under section 80IC of the Income-tax Act, 1961 could be denied merely because audit report in Form 10CCB was uploaded after the due date, though it was available before processing under section 143(1).

Analysis: The return was filed within the extended due date and the audit report in Form 10CCB had been obtained before the due date under section 44AB, though it was uploaded with the return. The denial was based only on belated electronic filing. The audit report was on record before processing under section 143(1), and the requirement to file the report along with the return was treated as directory rather than mandatory. On that basis, delay in upload did not defeat the substantive claim for deduction. The rectification rejection was therefore unsustainable.

Conclusion: The issue was decided in favour of the assessee, and the deduction under section 80IC was held allowable despite the delayed filing of Form 10CCB.

Ratio Decidendi: Where the statutory audit report is available before assessment or processing and the claim otherwise satisfies the substantive conditions, delayed filing of the report does not by itself nullify entitlement to deduction if the requirement is directory in nature.

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