DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2, GUWAHATI vs. AROMA INDIA PRIVATE LIMITED, ASSAM

ITA 48/GTY/2025Status: DisposedITAT Guwahati11 May 2026AY 2022-237 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the delay in filing Form 10CCB was due to technical glitches and substantial compliance was made before filing the return. It further noted that Section 143(1)(a)(ii) does not permit disallowance for delayed filing of such a form as it's not an 'apparent incorrect claim'.

What were the facts?

The assessee claimed deduction under Section 80-IE but faced technical difficulties uploading the required Form 10CCB by the due date. The form was eventually uploaded before filing the return of income, but the Assessing Officer disallowed the deduction under Section 143(1)(a)(ii).

What were the issues?

Whether the disallowance of deduction under Section 80-IE for delayed filing of Form 10CCB is permissible under Section 143(1)(a)(ii) when the delay was due to technical issues and substantial compliance was made.

Which sections of the Income-tax Act were involved?

Section 80-IE,Section 143(1)(a)(ii),Section 139(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, – GUWAHATI BENCH

Before: Shri Sonjoy Sarma & Shri Rakesh Mishra

Per Sonjoy Sarma, Judicial Member:

The present appeal filed by the Revenue is directed against the order dated 26.12.2024 passed by the Commissioner of Income Tax (Appeal) [hereinafter referred to as the ‘Ld. CIT(A)] u/s 250 of the Income Tax Act, 1961 (the ‘Act’) for the assessment year 2022-23. 2. The assessee is engaged in the business of manufacturing IMFL, and commercial production commenced from 28.08.2014. Therefore, the assessee became eligible for deduction u/s 80-IE of the Act for a period of 10 years from the initial assessment year 2015-16 and has consis

The order continues below.

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