Singularity Labs Private Limited vs. ITO
Parties Involved
Facts Summary
The assessee, Singularity Labs Private Limited, is a company engaged in software development services located in a Special Economic Zone (SEZ). The assessee filed its income return on 29.11.2019, claiming a deduction under section 10AA of the Income-tax Act, 1961 amounting to Rs.3,69,46,950/-. The Centralized Processing Centre (CPC) issued a communication on 31.12.2019 proposing an adjustment under section 143(1)(a) of the Act, denying the deduction due to a delay of 5 days in e-filing Form 56F. The assessee argued that the signed physical copy of Form 56F was received before the due date and the delay in e-filing was due to technical difficulties. The assessee appealed to the Commissioner of Income Tax (Appeals) (CIT(A)), which dismissed the appeal. The assessee then appealed to the Income Tax Appellate Tribunal (ITAT).…
Decision in favour of
Partly Assessee / Partly Revenue
Legal Issues
- 1. Whether the disallowance of Rs. 3,69,46,856/- under section 143(1)(a) of the Act is sustainable.
- 2. Whether the minor delay of 5 days in filing Form 56F should be condoned.
Judgment Outcome
Decided in favour of Partly Assessee / Partly Revenue.
Precedents Relied Upon
6 precedents cited in this judgement.
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