ALAGU AIR PRODUCTS PRIVATE LIMITED,COIMBATORE vs. DCIT, CORP CIRCLE 1, COIMBATORE
What were the facts?
The assessee claimed a deduction under Section 80IA(4)(iv) but could not file Form 10CCB due to technical glitches on the e-filing portal. The Assessing Officer disallowed the deduction, and the CIT(A) dismissed the assessee's appeal.
What did the Tribunal hold?
The Tribunal held that the assessee's inability to file Form 10CCB was due to system glitches and not the assessee's fault. Following jurisdictional High Court precedents, the Tribunal ruled that procedural lapses should not lead to the denial of deductions under benevolent provisions like Section 80IA.
What were the issues?
Whether the disallowance of deduction under Section 80IA(4)(iv) is justified due to the non-filing of Form 10CCB on the e-portal due to technical glitches. Whether procedural lapses in filing forms should lead to denial of deductions under benevolent sections.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, ‘C’ BENCH: CHENNAI
Before: HONOURABLE SHRI ABY T. VARKEY & SHRI GAGAN GOYAL
PER GAGAN GOYAL, AM: This is an appeal preferred by the assessee against the order of the Ld.
Commissioner of Income Tax (A) / Addl / JCIT(A)-1, (hereinafter referred as the ‘Ld.CIT(A)’) Lucknow dated 04.10.2024 for the assessment year (hereinafter referred as the ‘AY’) 2022-23. GROUNDS OF APPEAL 1)
The Ld. CIT (A) / NFAC, has e
The order continues below.
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More judgments on Section 80IA(4)(iv)
- Rns Power Limited, Bengaluru vs Deputy Commissioner of Income Tax…ITA 1421/BANG/2025[2020-21]Status: Disposed17 Feb 2026AY 2020-21
- Mulakala Mohan Krishna, Hyderabad vs DCIT., Circle-3(1), HyderabadITA 432/HYD/2025[2021-22]Status: Disposed8 Oct 2025AY 2021-22
- Gujarat Guardian Ltd., New Delhi vs ACIT, Circle-10(2), New DelhiITA 1967/DEL/2018[2014-15]Status: Disposed27 Jun 2025AY 2014-15
- Gujarat Guardian Ltd., New Delhi vs ACIT, Circle-10(2), New DelhiITA 1966/DEL/2018[2013-14]Status: Disposed27 Jun 2025AY 2013-14
- ACIT, Circle-10(2), New Delhi vs Gujarat Guardian Ltd., New DelhiITA 1819/DEL/2018[2014-15]Status: Disposed27 Jun 2025AY 2014-15
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