For the assessment year 2020-21 the assessee filed the return of income on 00.00.21 am of 16-2-2021, i.e., with a delay of 21 seconds as against due on 15-2-2021 midnight. The Assessing Officer disallowed the claim under section 80IA and issued intimation under section 143(1) of the Act.  The application for condonation of delay was rejected by the Principal Commissioner. On writ allowing the petition the Court held that  the quantum of delay is not substantial, being 21 seconds. Undoubtedly the assessee ought not to have undertaken the exercise of filing of the return literally at the last second, but the 21 seconds delay could be considered to be a human error and condoned bearing in mind the dictates of substantial justice  the request for condonation has been considered not by a machine but a human being, who could well have considered the request in proper perspective condoning the delay of 21 seconds. The delay was  condoned. The return of the assessee shall be taken to have been filed in time with all consequences thereof.  (AY. 2020-21)