STEELBIRD HI TECH INDIA LIMITED vs. PRINCIPAL COMMISSIONER OF INCOME TAX DELHI 7 & ORS.

Instant writ petition impugns order dated 19.09.2025 passed by the Principal Commissioner of Income-Tax, PCIT, Delhi-7 (hereinafter referred to as ‘the Competent Authority’), whereby the petitioner’s application under Section 119(2)(b) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act of 1961’) was rejected.

Learned counsel for the petitioner submitted that the petitioner, who is engaged in the business of manufacturing, production and sale of protective headgear, notable helmets, pannier boxes, crash guards etc., filed its return of income for Assessment Year 2024-25 on 24.10.2024 and claimed accelerated deduction under Section 80JJAA of the Act of 1961. He submitted that the This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 10/08/2026 at 12:04:09

1 While informing that in order to claim accelerated deduction under Section 80JJAA of the Act of 1961, an assessee is required to furnish the prescribed Form 10DA at least a month before the due date of filing the return, which was supposed to be filed on 15.10.2024, he submitted that the petitioner obtained such certificate from the Chartered Accountant (CA) on 30.09.2024 and UDIN was generated on the very same date and was uploaded on the portal as assigned to the CA for electronic filing, but due to some communication gap, further processing was not done. The assessee was however under impression that it stood uploaded (process is complete). It is only later, that the petitioner realised that the Form had not been uploaded, which was subsequently uploaded on 16.12.2024-with a purported delay of 62 days.

Learned counsel submitted that because of the delay of 62 days, the petitioner’s claim of accelerated deduction under Section 80JJAA was rejected by way of intimation under Section 143(1)(a) of the Act. The petitioner, thus, moved an application under Section 119(2)(b) of the Act, seeking condonation of 62 days’ delay in filing Form 10DA.

Assailing the order impugned passed by the Competent Authority on 19.09.2025, learned counsel for the petitioner argued that a simple look at the order under challenge reveals that the Competent Authority has not even looked at the record properly. The reasons assigned therein are not at all relevant and relatable to the issue, which was involved in the case. He submitted that, in any event, the reasons which the petitioner has assigned for the delay of 62 days were bonafide and, thus, the Commissioner ought to have This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 10/08/2026 at 12:04:09

Mr. Puneet Rai, learned Senior Standing Counsel for the respondents vehemently opposed the petitioner’s prayer for setting aside the order impugned and submitted that the petitioner is a professionally managed company and is assisted by a CA and, therefore, the plea taken by it cannot be sustained in the era of e-filing.

Having heard learned counsel for the parties, we are of the view that the order impugned passed by the Competent Authority cannot be sustained in the eyes of law. A look at the order reveals a non-application of mind by the Competent Authority, inasmuch as the assessee’s case was that of seeking condonation of delay in filing Form 10DA, whereas the Commissioner has dealt with the case as if the same was a case of non-filing of the tax audit report. Non-filing of the tax audit report and delay in filing a statutory Form 10DA changes the entire gamut of the case and that is precisely what has led to rejection of petitioner’s application.

Had the Competent Authority seen the application properly, there was no reason for which the petitioner’s application could have been rejected. The contents of the petitioner’s application, which have been reproduced by the Competent Authority in the initial part of the order, clearly shows that the UDIN had been generated on 30.09.2024 by the petitioner’s CA and the same had been uploaded on the income-tax portal. It was only the subsequent formality, which remained pending at the assessee’s end. And that too, as a matter of fact, completed on 16.12.2024, albeit with a delay of 62 days. It was a case of bonafide delay. Because of such bonafide delay, the petitioner’s substantive right of getting additional/accelerated deduction has been denied.

We are, therefore, persuade to set aside the impugned order dated This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 10/08/2026 at 12:04:09

2025 passed by the Competent Authority and allow the application dated 07.04.2025 filed by the petitioner under Section 119(2)(b) of the Act of 1961 and condone the delay of 62 days in filing Form 10DA. The Assessing Officer (AO) is directed to take Form 10DA on record and consider the same in accordance with law and give accelerated deduction to the petitioner, if it is otherwise eligible and entitled. Needful be done within a period of four months from today.

The present petition stands allowed, along with pending application. DINESH MEHTA, J. RAJNEESH KUMAR GUPTA, J. AUGUST 6, 2026/v This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 10/08/2026 at 12:04:09