Deduction under Section 80IBA allowed despite 16-day delay due to COVID-19, emphasizing fair treatment and natural justice

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....The ITAT allowed the assessee's appeal, holding that denial of the deduction claimed under section 80IBA solely due to belated filing of the income tax return by 16 days was unjustified. The tribunal found that the assessee had a reasonable and bona fide cause for delay, attributable to the Covid-19 pandemic, and had made substantial compliance. The addition was made without issuing any show cause notice, violating principles of natural justice. The deduction was admissible on the facts, and the specific amount was computed accordingly. The tribunal emphasized that technical non-compliance should not result in denial of substantive rights, and the assessee should not be burdened with taxes not legally payable. Consequently, the appeal was allowed, affirming the entitlement to the claimed deduction despite the delayed filing.....