Tax Deduction Denied for Late Filing Challenged; Section 10AA Doesn't Restrict Delays in Filing u/s 139(1.

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....Deduction u/s 10AA - Disallowance for the reason that the assessee had filed return of income belatedly and not within the time limit prescribed u/s 139(1) - When the Legislature has omitted such a restriction in section 10AA in its wisdom, it is not for the A.O. nor the CIT(A) to prescribe such a conditionality and impose it on an assessee. - AT....