Filing IT form 10e without filing previous year IT returns

Hello,
one of my friend has received arrears of salary previous year and wants to file form 10e to get exemption under section 89(1).
unfortunately, he has not filed his Income tax returns for the past three years preceeding the previous year for which he proposes to claim exemption in form 10e.
He is a salaried person and his income is above the exemption limit in all the three previous years and his employer has deducted TDS and the same is available in form 16 and 26AS for the past three previous years.

My question is
1. can form 10e filed taking into account the arrear pertaining to three previous years even though IT return is not filed but tax has been paid via TDS ?

Thanks in advance