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AI Drafter

Generate professional replies to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.

Step 1 – Issue Identification & Review

The AI analyses your query, notice, order, or uploaded documents and identifies the key issues involved.

• Review the issues identified by the AI
• Add, edit, remove, or refine issues as required


Step 2 – Draft Generation

Once you approve the issues, the AI performs issue-wise legal research and prepares a structured draft response.

• Relevant statutory provisions
• Judicial precedents and Supreme Court, High Court and other citations
• Issue-wise legal analysis
• Practical arguments and supporting content
• Professionally structured draft ready for further review.

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        Case ID :

        2026 (5) TMI 845 - AT - Income Tax

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        Section 11 exemption survives when Form 10B is filed before the return due date, despite missing an earlier filing deadline. Exemption under section 11 cannot be denied where the prescribed audit statement, Form No. 10B, is furnished on or before the due date for filing the ...
                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.

                              Section 11 exemption survives when Form 10B is filed before the return due date, despite missing an earlier filing deadline.

                              Exemption under section 11 cannot be denied where the prescribed audit statement, Form No. 10B, is furnished on or before the due date for filing the return under section 139(1), even if it was filed after an earlier internal filing date. On the stated facts, the form was uploaded before the extended return due date, so the statutory condition in section 11(2)(a) read with section 13(9) was satisfied. Accordingly, disallowance at the processing stage was not sustainable, and the assessee remained entitled to the exemption claim.




                              Issues: Whether the assessee was entitled to exemption under section 11 despite the Form No. 10B having been filed after the prescribed form-filing date but before the due date for filing the return of income.

                              Analysis: The assessee had filed Form No. 10B on 28.01.2021 and the return of income on 04.02.2021, while the due date for furnishing the return under section 139(1) stood extended to 15.02.2021. On these facts, the form was on record before the due date for filing the return. The statutory scheme under section 11(2)(a) and section 13(9) permits denial of exemption only where the prescribed statement is not furnished on or before the due date under section 139. Since the form was filed within that extended due date, the disallowance made at the processing stage was not sustainable.

                              Conclusion: The assessee was entitled to the claim under section 11, and the Revenue's challenge failed.

                              Ratio Decidendi: Where the prescribed statement or audit form for exemption is furnished on or before the due date for filing the return under section 139(1), the exemption cannot be denied merely because it was filed after an earlier internal deadline but before the return due date.


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                              ActsIncome Tax
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