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    <title>2025 (8) TMI 1806 - ITAT AHMEDABAD</title>
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    <description>Belated filing of the return did not, for assessment year 2017-18, bar deduction under section 80P(2)(a)(i) and section 80P(2)(d) where the claim was raised before the Assessing Officer during assessment proceedings; the denial on technical delay was therefore unsustainable. The assessment framed under section 144 was also found vitiated because the assessee had responded to notice and filed its return, yet the material was not properly considered and the assessment was completed without effective opportunity, offending natural justice. The deduction was thus allowed on merits, except for the bank interest element admitted as taxable, and the disallowance was set aside to that extent.</description>
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      <title>2025 (8) TMI 1806 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=468552</link>
      <description>Belated filing of the return did not, for assessment year 2017-18, bar deduction under section 80P(2)(a)(i) and section 80P(2)(d) where the claim was raised before the Assessing Officer during assessment proceedings; the denial on technical delay was therefore unsustainable. The assessment framed under section 144 was also found vitiated because the assessee had responded to notice and filed its return, yet the material was not properly considered and the assessment was completed without effective opportunity, offending natural justice. The deduction was thus allowed on merits, except for the bank interest element admitted as taxable, and the disallowance was set aside to that extent.</description>
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