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Issues: Whether the assessee's electronically filed audit reports in Form 3CLA satisfied the time requirement under Rule 6(7A)(c) for issuance of Form 3CL for the relevant assessment years.
Analysis: Rule 6(7A)(c) requires the audit report in Form 3CLA to be furnished electronically to the prescribed authority by the due date for filing the return of income. The prescribed authority had registered as an external agency on the income-tax e-filing portal and accepted that Form 3CLA uploaded by the assessee could be accessed through that portal. The reports for the two relevant years were uploaded before the applicable return-filing due dates, and the further material sought by the authority was also supplied within the time subsequently granted.
Conclusion: Electronic filing of Form 3CLA on the income-tax portal within the applicable return-filing due date constitutes compliance with Rule 6(7A)(c); rejection of the applications as delayed was unsustainable.