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Issues: Whether deduction under section 80P could be denied for assessment year 2018-19 on the ground that the return was not furnished within the due date under section 139(1), in view of section 80AC as amended with effect from 01.04.2018.
Analysis: The return claiming deduction under section 80P was filed only in response to notice under section 148 and not within the due date prescribed under section 139(1). For assessment year 2018-19, section 80AC required that no deduction under Chapter VI-A under the heading "C.-Deductions in respect of certain incomes" be allowed unless the return was furnished on or before the due date under section 139(1). The assessee did not produce any basis for condonation of delay. The claim under section 80P was therefore barred by the statutory condition.
Conclusion: Deduction under section 80P was rightly disallowed and the issue was decided against the assessee. The penalty under section 270A, being consequential to the quantum addition, also stood sustained.