Procedural delay in Form 10DA filing cannot defeat section 80JJAA deduction when the form was on record before intimation.

Deduction under section 80JJAA could not be denied merely because Form 10DA was uploaded one day after the return, where the form was already on record before intimation under section 143(1) was issued. The Tribunal treated filing of the prescribed form as a procedural requirement and held that sufficient compliance existed once the form was available for verification before the intimation. It also held that the stricter approach applied to exemption claims was not apt for a deduction claim under section 80JJAA. The denial of deduction was unsustainable.

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Issues: Whether deduction under section 80JJAA of the Income-tax Act, 1961 could be denied merely because Form 10DA was uploaded one day after the return, when the form was on record before the intimation under section 143(1) was issued.

Analysis: The delay in filing Form 10DA was only one day and the form had been uploaded before the intimation under section 143(1) was passed. The Tribunal accepted the view taken in coordinate bench decisions that the filing of the prescribed form is a procedural requirement and that sufficient compliance exists when the form is available for verification before the assessment or intimation is made. The reliance placed on the strict approach applied in the context of exemption provisions was held inapplicable to a claim for deduction under section 80JJAA.

Conclusion: The denial of deduction under section 80JJAA was unsustainable, and the assessee was entitled to the deduction of Rs. 16,76,625/-.

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