ITAT Bangalore Allows Section 80JJAA Deduction — Rules CIT(A) Applied Wrong Due Date for Return Filing

Case Overview

Case Name: Mindteck (India) Limited Vs DCIT (ITAT Bangalore)
Assessment Year: 2018–19
Forum: Income Tax Appellate Tribunal, Bangalore
**ITA No.😗* 2077/Bangalore/2025
Order Date: 18th June, 2026

The Income Tax Appellate Tribunal (ITAT), Bangalore, rendered a significant ruling in favour of the assessee by directing the Assessing Officer to grant a deduction of ₹11,90,545 under Section 80JJAA of the Income Tax Act, 1961. The core issue revolved around whether the return of income and Form No. 10DA had been filed within the prescribed due date — a mandatory condition for claiming the benefit under Section 80JJAA. The Tribunal conclusively found that the Commissioner of Income Tax (Appeals) had applied an incorrect due date while rejecting the assessee's claim, making the disallowance legally unsustainable.

Background and Facts of the Case

Mindteck (India) Limited, the assessee-company, filed its return of income for Assessment Year 2018–19 on 30.11.2018, declaring a total income of ₹7,95,23,620/. Along with the return, the assessee also filed Form No. 10DA as mandated under Rule 19AB of the Income Tax Rules, 1962, and additionally disclosed the relevant deduction claim in Form No. 3CD.

During the processing of the return under Section 143(1) of the Income Tax Act, 1961, certain prima facie adjustments were carried out, which included the disallowance of the deduction of ₹11,90,545 claimed under Section 80JJAA. Subsequently, a notice under Section 143(2) was issued to the assessee on 22.09.2019, which eventually resulted in the Assessment Order dated 15.02.2021 passed under Section 143(3). In the said assessment order, the Assessing Officer retained the assessed income at the returned income figure, but notably, the computation sheet erroneously reflected the aggregate income at ₹8,37,41,850 — a figure adopted from the intimation issued under Section 143(1) rather than the return filed by the assessee.

Proceedings Before the CIT(A)

Aggrieved by the disallowance, the assessee preferred an appeal before the National Faceless Appeal Centre, Delhi (the CIT(A)). The denial of deduction under Section 80JJAA was raised as Ground No. 5 in that appeal.

Before the CIT(A), the assessee argued that: