VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — section 80AC and section 115JC: a late return destroys the section 80LA claim, and AMT still bites at nine per cent
CBDT Circulars & InstructionsCuts both wayss.80ACs.115JCs.115JC(2)s.115JC(4)s.115JC(5)s.80LAs.139(1)s.44ABs.10AAs.35AD

Statutory position — section 80AC and section 115JC: a late return destroys the section 80LA claim, and AMT still bites at nine per cent

We missed the section 139(1) due date by a week and the IFSC unit's whole income is covered by section 80LA. Is the deduction still available, and does alternate minimum tax apply on top?

We missed the section 139(1) due date by a week and the IFSC unit's whole income is covered by section 80LA. Is the deduction still available, and does alternate minimum tax apply on top?

On the first question, no. Section 80AC provides that for an assessment year commencing on or after 1 April 2018, where any deduction is admissible under any provision of Chapter VI-A under the heading 'C.—Deductions in respect of certain incomes', no such deduction shall be allowed unless the assessee furnishes a return of his income for that assessment year on or before the due date specified under section 139(1). Section 80LA sits in that Part of Chapter VI-A, so a return filed even a day late costs the whole deduction. On the second, alternate minimum tax under section 115JC does apply to a person other than a company, and section 115JC(2)(i) adds back deductions claimed under any section in that same Part C — but section 115JC(4)(i) substitutes nine per cent for eighteen and one-half per cent where the person is a unit located in an International Financial Services Centre deriving its income solely in convertible foreign exchange.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2018-04-01, reported as Income-tax Act 1961, s.80AC, as printed on the Income-tax Department's section page carrying the year stamp 2024 (No. 2); s.115JC, as printed on the Department's section page carrying the year stamp 2025. It bears on section 80AC, section 115JC, section 115JC(2), section 115JC(4), section 115JC(5), section 80LA, section 139(1), section 44AB, section 10AA, section 35AD of the Income Tax Act 1961, in Deductions & Disallowances and Assessment & Scrutiny matters.

Still good law. The text of section 80AC was read on four separate year-stamped departmental pages — 2020, 2021, 2023 and 2024 (No. 2) — and came back in identical words on all four, which is the corroboration relied on; no page with a 2025 stamp was located for this section, so I cannot exclude a later amendment, and I did not read the Department's amendment footnotes for it. Section 115JC was read on the page carrying the year stamp 2025 and again on the page carrying the year stamp 2024 (No. 1), returning identical text. Judicial treatment of section 80AC's rigour was only partially checked this pass: an indiankanoon phrase search for "Deduction not to be allowed unless return furnished" on 8 September 2026 returned 155 results, which were not worked through, so whether any High Court has read a reasonable-cause exception into the section, or considered its application to a return filed under section 139(4), remains unresolved and is a proper target for a separate entry. The current text of section 80AC was separately confirmed word-for-word against the indiankanoon bare-Act text (doc 34883764), which also records that the section was substituted by the Finance Act 2018 (Act No. 13 of 2018) dated 29 March 2018 — the amending Act the Department's page does not name. Section 115JC could NOT be confirmed on any route independent of the Department: indiankanoon's section 115JC page (doc 49425645) returned HTTP 403 on two attempts. Indirect support only: an indiankanoon search shows section 39 of the Finance Act 2018 as the source of the nine per cent rate for a unit in an International Financial Services Centre.

Why it matters

These are the two provisions that turn a correctly computed section 80LA claim into a demand. The section 80AC point is absolute in its terms: there is no reasonable-cause proviso in the section, and it is not a defect that section 139(9) or a condonation of delay in filing addresses, because the bar is tied to the due date under section 139(1) and not to the validity of the return. It has also widened over time — the earlier form of the section named only sections 80-IA, 80-IAB, 80-IB, 80-IC, 80-ID and 80-IE, and the current limb (ii) covers ANY deduction under Part C of Chapter VI-A for assessment years commencing on or after 1 April 2018, which is how section 80LA came within it. On the AMT point, the arithmetic is what surprises: the deduction is added back into adjusted total income by section 115JC(2)(i), so an IFSC unit with a full section 80LA claim can still have a substantial adjusted total income, taxed at nine per cent instead of eighteen and one-half per cent, and the concessional rate is conditional on the unit deriving its income SOLELY in convertible foreign exchange — a single rupee-denominated income stream can put the unit back at the full rate. Two limits on section 115JC should be kept in view: by its own opening words it applies to a person 'other than a company', and by sub-section (5) it does not apply where the person has exercised the option under section 115BAC(5), section 115BAD(5) or section 115BAE(5), or where tax is computed under section 115BAC(1A). What happens to a COMPANY that is an IFSC unit is a minimum alternate tax question under a different provision, which was not read this pass and about which nothing is said here. One qualification on the section 80AC point, which was not available when this entry was first written. In Volark Leasing IFSC Pvt. Ltd. v. ACIT (ITAT Ahmedabad "C" Bench, I.T.A. No. 357/Ahd/2025, AY 2023-24, order dated 29 October 2025) the assessee's return was filed on 31 December 2023, beyond the extended section 139(1) due date of 31 October 2023, and the Tribunal nonetheless directed the Assessing Officer to grant the section 80LA deduction — but the dispute there was framed entirely around the late filing of Form 10CCF under section 80LA(3), and SECTION 80AC WAS NEITHER ARGUED NOR CONSIDERED. The order is therefore no authority against the section 80AC bar, and should not be cited as though it were; but it does show that the bar is not always taken, and it is the only decision located on an IFSC unit's section 80LA claim.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

Not yet CA-verified. This entry was found through the sources listed under the Sources tab, and the summary reflects what those sources say. Nobody has yet read the full judgment and signed it off. Check the source before relying on it.

Read aloud by your device. Press again to stop.

Related

Other authorities on the same sections.