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    <title>2026 (5) TMI 826 - ITAT AHMEDABAD</title>
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    <description>Entitlement to exemption under sections 11 and 12 was upheld where the audit report in Form 10B had been dated and filed along with the return, and both were already on record when the return was processed. The Tribunal treated the filing requirement as procedural and held that, even if there was any delay during the peak Covid period, it should not have been viewed adversely where the report was available to the Department. Denial of exemption on a late-filing objection was described as hyper-technical, and the disallowance made in rectification proceedings under section 154 was held unsustainable.</description>
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      <link>https://www.taxtmi.com/caselaws?id=791624</link>
      <description>Entitlement to exemption under sections 11 and 12 was upheld where the audit report in Form 10B had been dated and filed along with the return, and both were already on record when the return was processed. The Tribunal treated the filing requirement as procedural and held that, even if there was any delay during the peak Covid period, it should not have been viewed adversely where the report was available to the Department. Denial of exemption on a late-filing objection was described as hyper-technical, and the disallowance made in rectification proceedings under section 154 was held unsustainable.</description>
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