Procedural delay cannot defeat substantive exemption

Can an 18-day delay in filing Form 10B wipe out an otherwise valid Section 12A exemption? Orissa High Court says no.

The delay occurred during the COVID period, the audit report was ultimately filed, and the Trust's explanation was found genuine. 

The Court held that Section 119(2)(b) discretion cannot be exercised mechanically. Where genuine hardship is shown, procedural delay should not defeat substantive exemption