Section 119(2)(b) of the Income Tax Act

Income-tax Act, 2025: s.239

Section 119(2)(b) falls under section 119 of the Income-tax Act, 1961, which corresponds to section 239 (Instructions to subordinate authorities) of the Income-tax Act, 2025.

Read section 239 of the 2025 Act

Correspondence checked against the ICAI tabular mapping of the two Acts and the BharatTax.co section commentary.

The decision most relied on for Section 119(2)(b) is CIT v. G.M. Knitting Industries (P.) Ltd. (376 ITR 456), cited in 221 of the 980 judgments on BharatTax that turn on this section.

Leading authorities on Section 119(2)(b)

CIT v. G.M. Knitting Industries (P.) Ltd.
376 ITR 456 · 2015 · Supreme Court
221
citing judgments

The requirement to file a certificate or form (e.g., Form 10CCB, 10-IC) along with the return of income for claiming a deduction (e.g., under sections 80-IB, 115BAA) is directory regarding its timing. Such a deduction is allowable if the requisite form is filed before the final order of assessment, as procedural requirements should not override substantive benefits.

CIT v. Gujarat Oil & Allied Industries
201 ITR 325 · 1993 · High Court
195
citing judgments

The requirement to file an audit report along with the income tax return, as specified in provisions like Section 80J(6A) or 80-IA(7), is directory and not mandatory. Substantial compliance is achieved if the audit report is submitted at any time before the assessment is framed or completed, and benefits should not be denied merely due to a delay in furnishing it.

PCIT v. Wipro Ltd.
140 Taxmann.com 223 · 2022 · Supreme Court
192
citing judgments

Exemption provisions under Chapter III, such as Section 10B(8), must be interpreted strictly, and any claim for such exemptions must be made in the return of income. The principles governing Chapter III (incomes not forming part of total income) differ from those for Chapter VIA (deductions in computing total income).

CIT v. Contimeters Electricals (P.) Ltd.
317 ITR 249 · 2009 · High Court
140
citing judgments

The requirement to file an audit report along with the return of income under section 80-IA(7) and similar provisions is directory, not mandatory. Such a report suffices if filed at any time before the assessment is framed.

Sarvodaya Charitable Trust v. ITO (Exemption)
125 Taxmann.com 75 · 2021 · High Court
129
citing judgments

The filing of Form 10B for claiming exemption under sections 11 and 12 is directory, not mandatory. A delay in filing Form 10B can be condoned, and exemption cannot be denied solely on this ground if the assessee satisfies other conditions and shows sufficient cause.

Ms. Brinda Ramakrishna v. ITO
135 Taxmann.com 358 · 2022 · ITAT
109
citing judgments

The filing of Form 67 for claiming Foreign Tax Credit (FTC) is a directory requirement, not mandatory. Rule 128(9) does not provide for disallowance of FTC due to delay in filing this form. Double Taxation Avoidance Agreements (DTAAs) override domestic law.

ATION OF THE CITY OF AHMEDABAD AND OTHERS. 39. (1978) 3 SCC 544: MADHAV HAYAWADANRAO HOSKOT v. STATE OF MAHARASHTRA. 40
3 SCC 261 · 1997 · Reported
106
citing judgments

The constitutional validity of an enactment can be supported by arguments that it would pass legal tests.

CIT v. Shivanand Electronics
209 ITR 63 · 1994 · High Court
100
citing judgments

The requirement to file an audit report along with the return of income for claiming specified deductions, such as under Section 80J or 80-IA, is directory and not mandatory. Such an audit report can be filed at any time before the assessment is framed or completed under Section 143(1).

AA520 Veerappampalayam Primary Agricultural Cooperative Credit Society Ltd. v. Deputy Commissioner of Income Tax
138 Taxmann.com 571 · 2022 · High Court
78
citing judgments

The Centralized Processing Centre (CPC) can deny deductions claimed under Chapter VI-A, such as Section 80P, during the processing of a return under Section 143(1) if conditions for claiming such deductions, including filing the return by the due date as per Section 80AC, are not met.

CIT v. Mayur Foundation
274 ITR 562 · 2005 · High Court
68
citing judgments

The Gujarat High Court held that Form No. 10, for exercising the option under section 11(2) to accumulate income, can be submitted during assessment proceedings, including before the Income Tax Appellate Tribunal, which is a continuation of assessment proceedings. Such submission constitutes sufficient compliance for claiming exemption under section 11.

Judgments on Section 119(2)(b)

Punjab Municipal Infrastructure Development Company, Chandigarh vs. DCIT Exemption Circle 1, Chandigarh

The appeal stand allowed for statistical purposes

ITA 593/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh25 Feb 2026AY 2016-17

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं. / Ita No.593/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2016-17) M/S Punjab Municipal Infrastructure Dcit Exemption Circle 1, 5Th Floor Development Company बनाम/ Plot No. 3, 5Th Floor C. R. Building, Vs. Punjab Municipal Bhawan, Sector – 17E Chandigarh - 160022 Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcp-8185-M (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Navdeep Monga (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Meenakshi Vohra (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 25-02-2026 घोषणाकीतारीख /Date Of Pronouncement 25-02-2026 : आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2016-17 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac [Cit(A)] Dated 25-02-2025 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S 143(3) Of The Act On 26-11-2018. Having Heard Rival Submissions, The Appeal Is Disposed-Off As Under.

For Appellant: Sh. Navdeep Monga (Advocate) – Ld. ARFor Respondent: Smt. Meenakshi Vohra (CIT) – Ld. DR
Section 11(2)Section 119(2)(b)Section 143(3)

Ameenamma Charitble Trust, Anantapur vs. ITO, (Exemption) Ward-Tirupati, Tirupati

In the result, appeal filed by the assessee Trust is partly allowed in terms of our aforesaid observations

ITA 1841/HYD/2025[2016-17]Status: DisposedITAT Hyderabad20 Feb 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1841/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Ameenamma Charitable Vs. Income Tax Officer Trust, (Exemption) Ward – Anantapur. Tirupati. Pan: Aaeta7403P (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ka Sai Prasad, Ca राज" व "ारा/Revenue By: Shri K Vamsi Krishna, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 04/02/2026 घोषणा की तारीख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Trust Is Directed Against The Order Passed By The Additional/Joint Commissioner Of Income Tax (Appeals)-1, Chennai, Dated 03/10/2025, Which In Turn Arises From The Order Passed By The Income Tax Officer, Exemption Ward, Tirupati (For Short, “Ao”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 14/12/2018 For The Assessment Year (Ay) 2016-17. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

For Appellant: Shri KA Sai Prasad, CAFor Respondent: Shri K Vamsi Krishna, Sr.AR
Section 11Section 11(1)Section 11(2)Section 115BSection 12ASection 13(9)Section 139(1)Section 143(2)Section 143(3)Section 250

The Triplicane Coop Credit Society Ltd., Chennai vs. ITO, Ward-9(1), Chennai

ITA 2992/CHNY/2025[2020-21]Status: DisposedITAT Chennai17 Feb 2026AY 2020-21

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2992&2993/Chny/2025 निर्धारण वर्ष/Assessment Year: 2020-21 & 2021-22 The Triplicane Cooperative Credit Society Ltd., Old No.35, New No.73, Bharathi Salai, Triplicane, Chennai - 600 005. Pan: Aaaвт 2681E (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Appellant By प्रत्यर्थी की ओर से /Respondent By सुनवाई की तारीख /Date Of Hearing घोषणा की तारीख /Date Of Pronouncement The Income Tax Officer, Vs. Ward-9(1), Chennai. (प्रत्यर्थी/Respondent) Mr. B. Suresh, C.A Ms. R. Anitha, Addl. Cit 12.02.2026 17.02.2026 Per Padmavathy.S, A.M: आदेश / Order These Appeals By The Assessee Are Against The Separate Orders Of The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi, (In Short "Cit(A)") Passed U/S. 250 Of The Income Tax Act, 1961 (In Short "The Act") Both Dated 13.08.2025 For Assessment Year (Ay) 2020-21 & 2021-22. The Common Issue Contended In Both These Appeals Pertain To The Denial Of Deduction U/S.80P(2)(D) For The Interest Received From Chennai Central Cooperative Bank Ltd.

Section 139(1)Section 148Section 250Section 80ASection 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

P & R Engineering Services Private Limited., New Delhi vs. Circle 19(1), Delhi, DCIT, New Delhi, India

In the result, appeal of the assessee is allowed

ITA 4537/DEL/2025[2018-19]Status: DisposedITAT Delhi11 Feb 2026AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] P & R Engineering Service Vs. Dcit Pvt. Ltd., 89, Lok Nayak Circle-19(1) Apartment, Rohini Courts, New Delhi S.O. Rohini Courts, North West Delhi, New Delhi- 110085. Pan-Aaccp0484E Appellant Respondent Appellant By Shri V.K. Agarwal, Ar & Shri Hrithik Lamba, Adv. Respondent By Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 03.02.2026 Date Of Pronouncement 11.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 03.07.2025 Of Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2017-18/10031831 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 11.02.2021 Passed U/S 143(3) R. W. Sections 143(3A) & 143(3B) Of The Act Pertaining To Assessment Year 2018-19. 2. Brief Facts Of The Case Are That Assessee Has Claimed Deduction U/S 80-Ia Of The Act Of Inr 5,62,48,491/- Which Was Disallowed By The Ao For The Sole Reason That The Return Of Income Was Filed Belatedly On 30.03.2019 Though The Same Has To Be Filed Upto 31.10.2018 In Terms Of The Due Date As Per Section 139(1) Of The Act. Ld. Cit(A) Confirmed The Said Disallowance & Dismissed The Appeal Of The Assessee.

Section 119(2)(b)Section 139(1)Section 139(4)Section 143(3)Section 250Section 80Section 801ASection 80ASection 80I