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    <title>2025 (2) TMI 1566 - ITAT DELHI</title>
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    <description>Deduction under Section 80IAC was sustained where the audit report in Form 10CCB was obtained before the return-filing deadline but could not be uploaded timely because of a departmental portal malfunction. The assessee attempted online filing, sent the physical report to the Assessing Officer, emailed it to CPC, and later completed the upload. Documentary evidence supported the technical failure and the assessee&#039;s bona fide efforts to comply. Timely electronic filing of Form 10CCB was treated as capable of condonation in appropriate circumstances, with substantial compliance and equitable relief applying where a technical delay was beyond the assessee&#039;s control. The disallowance was deleted and the deduction claim upheld.</description>
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      <title>2025 (2) TMI 1566 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=466922</link>
      <description>Deduction under Section 80IAC was sustained where the audit report in Form 10CCB was obtained before the return-filing deadline but could not be uploaded timely because of a departmental portal malfunction. The assessee attempted online filing, sent the physical report to the Assessing Officer, emailed it to CPC, and later completed the upload. Documentary evidence supported the technical failure and the assessee&#039;s bona fide efforts to comply. Timely electronic filing of Form 10CCB was treated as capable of condonation in appropriate circumstances, with substantial compliance and equitable relief applying where a technical delay was beyond the assessee&#039;s control. The disallowance was deleted and the deduction claim upheld.</description>
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      <pubDate>Mon, 24 Feb 2025 00:00:00 +0530</pubDate>
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