Company tax return filing after Rule 12(3) e-filing mandate: manual return can't fix late e-return; 80-IC deduction denied

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....Rule 12(3) made e-filing of returns by companies mandatory with effect from 14.05.2007, and neither s.139 nor the CBDT circulars preserved any general option for companies to file manual returns for AY 2008-09. The limited relaxations cited (e.g., Settlement Commission-related difficulty and non-resident agents) did not apply to a company assessee. Given the statutory rule framework and the assessee's prior e-filing history, the manual return filed within time could not cure the belated electronic filing, and the view that CBDT circulars impermissibly overrode the statute was rejected; consequently, the denial of deduction u/s 80-IC on account of belated return was sustained. - HC....