Issues: Whether the long-term capital gain claimed from sale of shares of ACI Infocom Ltd. was bogus and liable to addition under section 68 of the Income-tax Act, 1961, along with disallowance of alleged commission expenditure under section 69C of the Income-tax Act, 1961.

Analysis: The assessee's purchase and sale of shares were supported by documentary evidence, including demat account records and sale through a SEBI-registered broker on a recognised stock exchange. The same scrip and similar facts had already been considered by coordinate benches, which held such gains to be genuine and eligible for exemption under section 10(38) of the Income-tax Act, 1961. The assessment was based on alleged modus operandi and suspicion, without independent inquiry or cogent material linking the assessee to any manipulation or accommodation entry. Mere abnormal price movement or general investigation reports were held insufficient to dislodge the documentary evidence produced by the assessee.

Conclusion: The addition treating the long-term capital gain as bogus was not justified, and the related commission addition under section 69C of the Income-tax Act, 1961 also failed. The additions were deleted and the appeal was allowed.

Ratio Decidendi: A documented share transaction executed through demat and stock exchange channels cannot be treated as bogus merely on suspicion or general allegations of price rigging unless the Revenue brings on record specific, cogent material disproving the assessee's evidence.

Issues: Whether the appellant contravened the FEMA provisions by failing to import goods or realize and repatriate the foreign exchange remitted for the imports, and whether the penalty required interference.

Analysis: The appellant remitted foreign exchange to an overseas supplier for import of shredded steel scrap, but the imports were not fully completed and a substantial part of the remittance remained unutilized. The attempt to justify adjustment through supplies and refunds routed through a different company was rejected because the entities were separate legal persons and there was no admissible evidence or RBI permission showing that third-party adjustments were permissible. The Tribunal also held that proceedings under customs law were independent and did not control liability under FEMA. However, on the facts and circumstances, the Tribunal found that the penalty imposed by the adjudicating authority was excessive and warranted reduction.

Conclusion: The appellant was held liable for contravention of Section 10(6) of FEMA read with Regulation 6(1) of the 2000 Regulations, but the penalty was reduced.

Final Conclusion: The appeal succeeded only to the extent of reduction in penalty, while the finding of contravention was maintained.

Ratio Decidendi: Foreign exchange remitted for a specific import purpose must be either applied to that purpose or lawfully realized and repatriated, and ad hoc third-party adjustments without admissible evidence or RBI cannot satisfy that obligation.

Issues: Whether the appellants had contravened the requirement to furnish documentary evidence of import in respect of the remittances and whether the penalty imposed on the company and its managing director called for interference.

Analysis: The Appellate Tribunal held that the appellants had been put on notice in 2002 and had failed to complete their response or produce alternative material to show that the relevant imports were actually made. The plea of delay and laches was rejected because the appellants had knowledge of the enquiry and still did not preserve or produce the necessary documents. The requirement under the FEMA framework and the RBI directions was treated as casting a duty on the importer to furnish evidence of import to the authorised dealer, while the authorised dealer was only required to follow up and report. The Tribunal also held that Section 42 of FEMA fastens liability on persons responsible for the conduct of the company's business during the period of contravention, and the managing director could not avoid responsibility in the absence of proof of due diligence.

Conclusion: The contravention and the liability of both appellants were upheld, but the quantum of penalty was found to be excessive and was reduced.

Final Conclusion: The appeals succeeded only to the extent of reduction of penalty, while the findings of contravention and responsible-person liability were maintained.

Ratio Decidendi: In proceedings under FEMA, an importer who is put on notice must furnish or preserve documentary proof of import, and failure to do so justifies adverse inference and penalty; persons responsible for the company's conduct are liable under Section 42 unless due diligence is shown, though the penalty may be reduced on proportionality grounds.

Issues: Whether the interim order granting release of the goods and vehicle on furnishing security required modification when the challenge related to confiscation under Section 130 and not merely detention under Section 129.

Analysis: The writ appeals turned on the distinction between detention and release proceedings under Section 129 and confiscation proceedings under Section 130. The impugned orders challenged confiscation orders, and once an order under Section 130 is passed, title to the goods and conveyance vests in the Government under sub-section (5). In that situation, the mechanism contemplated under Section 129 is no longer available, and the adjudication regarding confiscation, valuation, tax, penalty, interest and fine proceeds exclusively under Section 130. The Court found that the interim orders passed by the learned Single Judge, which imposed conditions for release, were consistent with the governing legal position and did not warrant modification.

Conclusion: The request to modify the interim orders was rejected; the distinction between Section 129 and Section 130 operated against the appellants, and the challenge failed.

Ratio Decidendi: Once confiscation is ordered under Section 130 and title to the goods vests in the Government, release based on the detention regime under Section 129 is not available, and interim relief must conform to the confiscation framework.

Issues: Whether income-tax dues relating to a period prior to approval of the resolution plan could be revived and recovered by passing an assessment order and demand notice after approval of the resolution plan under the Insolvency and Bankruptcy Code, 2016.

Analysis: The approved resolution plan expressly provided that all income-tax liabilities, whether assessed or unassessed, and all pending assessment or appellate proceedings relating to the period prior to the effective date would stand extinguished and terminated. The Court applied the settled principle that once a resolution plan is approved under Section 31 of the Insolvency and Bankruptcy Code, 2016, all claims not forming part of the plan stand frozen and extinguished, and no proceedings in respect of such pre-resolution claims can continue against the corporate debtor or the resolution applicant. The impugned assessment and demand related to Assessment Year 2011-12, which was long prior to approval of the resolution plan, and therefore the respondents had no authority to proceed further.

Conclusion: The pre-resolution income-tax dues stood extinguished, and the impugned assessment order and demand notice were liable to be quashed.

Ratio Decidendi: Upon approval of a resolution plan under Section 31 of the Insolvency and Bankruptcy Code, 2016, all claims and proceedings relating to pre-resolution liabilities that are not provided for in the plan stand extinguished and cannot be revived or enforced against the corporate debtor or resolution applicant.

Issues: Whether an ex parte assessment order passed without affording sufficient opportunity to reply to the show cause notice should be quashed and the matter remitted for fresh consideration.

Analysis: The assessment order was passed ex parte, and the record indicated that the petitioner did not receive adequate time to file a reply to the show cause notice. In these circumstances, continuing with the assessment without a proper opportunity to respond would offend the principles of natural justice. To secure a fair adjudication, the appropriate course was to set aside the order and restore the matter to the stage of issuance of show cause notice so that the petitioner could submit a reply and participate in the proceedings.

Conclusion: The ex parte assessment order was quashed and the matter was remitted to the competent authority for fresh consideration from the stage of show cause notice, with an opportunity to the petitioner to file a reply.

Ratio Decidendi: An ex parte tax assessment order passed without granting a real and sufficient opportunity to respond to the show cause notice is liable to be set aside and the proceedings remitted for fresh adjudication in compliance with natural justice.

Issues: Whether the impugned assessment order was liable to be set aside for non-consideration of the petitioner's reply and supporting documents, with the matter to be reconsidered by the competent authority.

Analysis: The petitioner's alternative prayer was not pressed. The remaining grievance was that the reply to the show cause notice and the accompanying documents had not been considered before passing the impugned order. The parties also accepted that the matter could be examined afresh by the competent authority on a fresh response, if filed, and that the authority should decide the claim by a speaking and reasoned order within a fixed time.

Conclusion: The impugned order was set aside and the competent authority was directed to consider the objections and documents, if filed within the stipulated time, and pass a speaking and reasoned order in accordance with law.

Ratio Decidendi: An order affecting tax credit cannot be sustained where the reply and supporting material filed in response to the notice have not been considered, and the matter must be decided afresh by a reasoned order after such consideration.

Issues: Whether GST collected on the sale of rejected wheat and paddy seeds was refundable and whether directions were required for processing and returning the amount.

Analysis: The amount had been deducted towards GST even though the basic liability to pay GST on the transaction was not in dispute. The Corporation itself did not dispute that the amount deducted was liable to be refunded, and the only explanation offered was that refund applications had been made to the tax department. In these circumstances, the department could not retain the amount any further. The Court therefore directed the Corporation to move the refund application in the appropriate form, after which the department was to release the refund forthwith, and the Corporation was then to pass the amount to the petitioner.

Conclusion: The GST amount was held refundable and directions were issued to secure refund to the petitioner, in favour of the assessee.

Final Conclusion: The writ petition was disposed of with a direction to complete the refund process and ensure payment of the collected GST amount to the petitioner.

Ratio Decidendi: Where tax collected is not legally payable and the liability is undisputed, the amount cannot be retained indefinitely and refund must be processed through the prescribed mechanism and passed on to the person from whom it was recovered.

Issues: Whether the impugned demand order was liable to be set aside for non-consideration of the petitioner's reply and supporting documents, with a direction for fresh adjudication in accordance with law.

Analysis: The petitioner did not press the challenge to the constitutional validity of the ITC restriction provisions. The controversy that survived concerned the demand order passed after issuance of the show-cause notice, where the petitioner's reply and documents were stated to have remained unconsidered. In these circumstances, the Court found it appropriate to set aside the impugned order and direct the competent authority to examine the objections and material afresh, and to pass a speaking and reasoned order after due consideration of the response to the notice within the time granted.

Conclusion: The impugned order was quashed and the matter was remitted for fresh consideration, which is in favour of the petitioner.

Ratio Decidendi: An adjudicatory demand order cannot be sustained where the reply and supporting material of the noticee have not been considered, and the matter must be decided afresh by a speaking and reasoned order after due consideration.

Issues: (i) Whether denial of registration under section 12AB was justified on the ground that the trust's activities were not charitable or genuine. (ii) Whether denial of approval under section 80G(5) was sustainable once registration under section 12AB was directed to be granted.

Issue (i): Whether denial of registration under section 12AB was justified on the ground that the trust's activities were not charitable or genuine.

Analysis: The trust's objects and activities were examined in the context of charitable purpose. Even if the activities did not fall strictly within education, they were held to fall within the wider category of general public utility. Receipt of nominal fees to meet expenses was not treated as commercial activity. No material was found to show that the activities were not genuine.

Conclusion: Denial of registration under section 12AB was not justified and the trust was entitled to registration from the date of application.

Issue (ii): Whether denial of approval under section 80G(5) was sustainable once registration under section 12AB was directed to be granted.

Analysis: The rejection of approval under section 80G(5) was based only on the refusal of registration under section 12AB. Once the refusal of registration was set aside, the basis for denial of approval no longer survived.

Conclusion: Denial of approval under section 80G(5) was not sustainable and approval was directed to be granted from the date of application.

Final Conclusion: The assessee succeeded in both appeals, with registration under section 12AB and approval under section 80G(5) directed to be granted.

Ratio Decidendi: A trust engaged in activities for a charitable object does not lose eligibility for registration merely because it charges nominal fees to recover expenses, and denial of ancillary approval cannot survive when it rests solely on an unsustainable refusal of registration.

Outcome: Special Leave Petition dismissed. The order notes that the limitation finding recorded by the Tribunal, including that the show cause notice was beyond the normal period and that the extended period was unavailable for want of suppression, had not been questioned before the High Court and no reason was found to entertain the petition.

Issues: Whether GST proceedings, show-cause notices, and the impugned order issued in the name of an amalgamated company that had ceased to exist after approval of the scheme of amalgamation were valid, and whether Section 87 of the Central Goods and Services Tax Act, 2017 could sustain such action.

Analysis: The amalgamation scheme had been approved by the National Company Law Tribunal, after which the original company ceased to exist and its registration was cancelled. The notices and the impugned order were nonetheless issued against that non-existent entity. In such circumstances, proceedings initiated against a dead or non-existent person are without jurisdiction. Section 87 of the Central Goods and Services Tax Act, 2017 governs liability arising in the interregnum contemplated by that provision, but it does not authorise issuance of notices or passing of assessment orders against an entity that has already ceased to exist after amalgamation.

Conclusion: The proceedings and the impugned order against the amalgamated entity were invalid and liable to be set aside, and the writ petitions were allowed.

Issues: (i) Whether the 2009 amendment inserting sections 7 to 13 of the Prevention of Corruption Act, 1988 in the schedule to the Prevention of Money Laundering Act, 2002 could not be applied retrospectively to properties acquired earlier; (ii) whether prior permission or intimation from the department was obtained for acquiring the immovable properties; (iii) whether attachment by the Enforcement Directorate was invalid because the properties had already been seized by the police or were under attachment in the criminal case; (iv) whether the appellants had lawful sources of income to acquire the immovable properties; (v) whether the properties covered by the will deed belonged to Killi Raghuramudu and were not liable to attachment; and (vi) whether the properties of the other appellants were liable to be released merely because they were not named as accused in the charge-sheet.

Issue (i): Whether the 2009 amendment inserting sections 7 to 13 of the Prevention of Corruption Act, 1988 in the schedule to the Prevention of Money Laundering Act, 2002 could not be applied retrospectively to properties acquired earlier?

Analysis: The relevant inquiry was held to be the date on which the property was projected or claimed as untainted and the act of money laundering occurred, not the date of the underlying scheduled offence. Money laundering was treated as an independent and continuing offence connected with the proceeds of crime, and the scheduled offence could pre-date the inclusion of the predicate offence in the schedule without defeating action under the 2002 Act.

Conclusion: The contention of retrospective inapplicability was rejected and the issue was decided against the appellants.

Issue (ii): Whether prior permission or intimation from the department was obtained for acquiring the immovable properties?

Analysis: The Tribunal found no reliable proof that prior permission or proper intimation had been obtained. The materials relied upon by the appellants were not treated as sufficient to dislodge the investigation findings, and the burden remained on the appellant to explain lawful acquisition. The issue was also viewed as requiring proof in the predicate criminal trial.

Conclusion: The issue was decided against the appellants.

Issue (iii): Whether attachment by the Enforcement Directorate was invalid because the properties had already been seized by the police or were under attachment in the criminal case?

Analysis: Search and seizure under the criminal process and provisional attachment under the 2002 Act were held to operate in different fields. The Tribunal relied on the overriding effect of the 2002 Act and held that prior police seizure did not bar attachment by the Enforcement Directorate.

Conclusion: The issue was decided against the appellants.

Issue (iv): Whether the appellants had lawful sources of income to acquire the immovable properties?

Analysis: The claimed sources such as sale proceeds, rental income, agricultural income, commission income, provident fund withdrawals, and housing loans were found not to be satisfactorily substantiated. The Tribunal accepted the enforcement version that the appellants failed to explain the acquisition of disproportionate assets from known legal income.

Conclusion: The issue was decided against the appellants.

Issue (v): Whether the properties covered by the will deed belonged to Killi Raghuramudu and were not liable to attachment?

Analysis: The Tribunal found that the will deed did not establish a lawful independent source for the properties. On the materials considered, the claim that the properties genuinely belonged to Killi Raghuramudu was not accepted, and the surrounding circumstances indicated that the properties were traceable to the tainted funds linked with the main appellant.

Conclusion: The issue was decided against the appellants.

Issue (vi): Whether the properties of the other appellants were liable to be released merely because they were not named as accused in the charge-sheet?

Analysis: The Tribunal held that attachment under the 2002 Act is not confined to persons named as accused in the scheduled offence. Property in the hands of any person can be attached if it represents proceeds of crime and is involved in the money-laundering process.

Conclusion: The issue was decided against the appellants.

Final Conclusion: The appeals failed on all substantive grounds and the confirmation of provisional attachment was sustained.

Ratio Decidendi: Money laundering under the Prevention of Money Laundering Act, 2002 is an independent and continuing offence, and attachment may be made against proceeds of crime even where the scheduled offence predates the inclusion of the predicate offence in the schedule or the holder is not an accused in the predicate offence.

Issues: Whether the petitioner was entitled to immediate zimma/release of the seized articles, or should first seek provisional release before the Investigating Officer under the applicable GST procedure.

Analysis: The prayer concerned seized electronic devices and documents. The applicable framework relied upon was Section 67(6) of the Central Goods and Services Tax Act, 2017, which permits provisional release of seized goods on execution of bond and furnishing of security or on payment of tax, interest and penalty, as prescribed. In view of that statutory mechanism, and since the petitioner had not first approached the Investigating Officer for zimma, the Court directed that the petitioner apply before the Investigating Officer, who would consider the request in accordance with law.

Conclusion: The petitioner was not granted direct release by the Court and was required to pursue provisional release before the Investigating Officer under Section 67(6) of the Central Goods and Services Tax Act, 2017.

Issues: (i) whether the respondent derived additional benefit of Input Tax Credit on introduction of GST and whether such benefit was passed on to homebuyers by commensurate reduction in prices; (ii) whether the respondent was liable to return the balance profiteered amount along with interest and GST, and whether penalty was attracted.

Issue (i): whether the respondent derived additional benefit of Input Tax Credit on introduction of GST and whether such benefit was passed on to homebuyers by commensurate reduction in prices.

Analysis: The respondent became entitled under GST to avail Input Tax Credit on both goods and input services, and the comparison of pre-GST and post-GST ITC to construction cost showed additional benefit. The methodology adopted by the DGAP on remand was found to be appropriate. Exclusion of service-related ITC was rejected. Denial by some buyers through email did not outweigh books of account, customer ledgers and credit notes. Contemporaneous pricing records also showed that the expected ITC benefit had been factored into sale prices in some cases, but not to the extent required under the anti-profiteering framework.

Conclusion: The respondent derived additional ITC benefit and did not fully pass it on; the revised computation of profiteering was upheld.

Issue (ii): whether the respondent was liable to return the balance profiteered amount along with interest and GST, and whether penalty was attracted.

Analysis: The balance profiteered amount was determined on the basis of revised computation, and excess benefit passed on to some buyers could not be adjusted against shortfall of others because entitlement under the anti-profiteering provision is buyer-specific. The profiteered amount was held to be inclusive of the corresponding GST component collected from buyers, and the recipient was entitled to restitution of the excess realisation with interest. Since the period of contravention extended beyond the commencement of the penalty provision, penalty was held to be attracted.

Conclusion: The respondent was directed to pass on the balance profiteered amount with GST and interest, and penalty was held to be attracted.

Final Conclusion: The respondent was found to have profited from unreduced prices after GST, the revised profiteering computation was accepted, and restitution with interest was ordered to the eligible homebuyers.

Issues: (i) Whether the deletion of the addition made under section 68 on account of unsecured loans called for interference under section 260A; (ii) Whether any substantial question of law arose in view of the concurrent factual findings and the low tax effect.

Issue (i): Whether the deletion of the addition made under section 68 on account of unsecured loans called for interference under section 260A.

Analysis: The assessee had produced material to establish the identity of the lender, its creditworthiness and the genuineness of the loan transactions, including PAN details, return of income, bank statements, audited accounts, NBFC registration, TDS records and evidence of repayment through banking channels. The fact that the credits in earlier years were carried forward also supported the view that the disputed amount was not entirely a fresh unexplained credit for the year under consideration. The appellate authorities concurrently found the lender to be a genuine entity and held that the onus under section 68 had been discharged. No perversity or misreading of evidence was shown.

Conclusion: The deletion of the addition under section 68 was upheld and no interference was warranted.

Issue (ii): Whether any substantial question of law arose in view of the concurrent factual findings and the low tax effect.

Analysis: The appeal challenged only concurrent findings on facts, and the Court found that the proposed questions were factual in nature rather than substantial questions of law. The tax effect was also below the prescribed monetary limit under the applicable CBDT circular, which independently supported non-entertainment of the appeal.

Conclusion: No substantial question of law arose and the appeal was not maintainable for consideration on merits.

Final Conclusion: The Revenue's challenge failed at the admission stage, and the assessee's relief as granted by the appellate authorities remained undisturbed.

Ratio Decidendi: In a section 260A appeal, concurrent findings that the assessee has established the identity, creditworthiness and genuineness of a loan creditor cannot be disturbed absent perversity, and a further bar arises where the tax effect is below the prescribed monetary limit.

Issues: (i) Whether the Principal Commissioner could invoke revisionary jurisdiction under Section 263 of the Income-tax Act, 1961 in relation to the quantum of deduction under Section 80-IA of the Income-tax Act, 1961 after appellate proceedings before the Commissioner (Appeals); (ii) Whether the specialized transfer pricing proceedings under Section 92CA of the Income-tax Act, 1961 excluded revision on the issue of allocation of head office expenses; (iii) Whether acceptance of the Direct Nexus theory amounted to a plausible view so as to bar revision under Section 263 of the Income-tax Act, 1961.

Issue (i): Whether the Principal Commissioner could invoke revisionary jurisdiction under Section 263 of the Income-tax Act, 1961 in relation to the quantum of deduction under Section 80-IA of the Income-tax Act, 1961 after appellate proceedings before the Commissioner (Appeals).

Analysis: The deduction under Section 80-IA was treated as involving distinct components, namely the valuation of receipts and the apportionment of expenses. The appellate authority had addressed the valuation side, but the allocation of common head office expenses was neither raised nor decided in appeal. On that basis, the bar of merger under Explanation 1(c) to Section 263 was held to be issue-specific and not a blanket prohibition against revision of unadjudicated matters.

Conclusion: The revisionary jurisdiction was not barred by merger and this issue was decided in favour of the Revenue.

Issue (ii): Whether the specialized transfer pricing proceedings under Section 92CA of the Income-tax Act, 1961 excluded revision on the issue of allocation of head office expenses.

Analysis: The transfer pricing officer's function was confined to valuation of the specified domestic transaction and arm's length price determination. The allocation of corporate overheads for computing eligible profits under Section 80-IA remained the primary duty of the assessing officer. Silence of the transfer pricing order on internal cost apportionment was not treated as a finding that bound the assessing officer. The assessment was also treated as abated for search purposes, giving the assessing officer plenary power to examine total income.

Conclusion: Transfer pricing proceedings did not bar revision on the expense allocation issue and this issue was decided in favour of the Revenue.

Issue (iii): Whether acceptance of the Direct Nexus theory amounted to a plausible view so as to bar revision under Section 263 of the Income-tax Act, 1961.

Analysis: A plausible view was held to require actual inquiry and application of mind. The record showed no meaningful scrutiny of the absence of head office expense allocation despite substantial corporate overheads. The Court treated this as non-inquiry rather than a permissible choice between two views, and held that a view unsupported by inquiry cannot attract protection from revision.

Conclusion: The Direct Nexus acceptance did not constitute a plausible view and this issue was decided in favour of the Revenue.

Final Conclusion: The revision under Section 263 survived, the assessee's appeals failed, and the matter was sent back for fresh assessment confined to proportionate allocation of common head office expenses.

Ratio Decidendi: Under Section 263 of the Income-tax Act, 1961, merger is confined to matters actually considered and decided in appeal, and an assessment founded on non-inquiry into a material component of a profit-linked deduction remains revisable notwithstanding transfer pricing proceedings or a claimed plausible view.

Issues: Whether penalty under section 272A(1)(d) of the Income-tax Act, 1961 could be sustained for initial non-compliance with notices under section 142(1) when the assessee subsequently furnished details and the assessment was completed under section 143(3) after considering those details.

Analysis: The assessees initially did not comply with some notices issued during assessment proceedings, but later furnished detailed replies and documentary support. The assessment order recorded that the replies were verified, found tenable, and accepted while completing the assessment under section 143(3). On that basis, the earlier lapse was treated as having been merged with and effectively cured by the subsequent compliance. In these circumstances, the default was considered to have been condoned by the Assessing Officer, leaving no basis for sustaining the penalty.

Conclusion: The penalty under section 272A(1)(d) was not leviable and was directed to be deleted, in favour of the assessee.

Issues: Whether the ex parte appellate order and the assessment additions required to be set aside and the matter restored for de novo adjudication in view of the assessee's non-consideration, the request for adjournment, and the requirement of a reasoned appellate order.

Analysis: The appellate order was passed ex parte without adjudicating the grounds on merits. The record indicated that the assessee had sought adjournment and extension of time to file submissions, and the explanation for non-compliance was supported by an affidavit showing reasonable cause. The Tribunal found the explanation bona fide and uncontroverted. It also noted that the property-related addition had already been restored in the case of the co-owner, and considered parity of facts, principles of natural justice, and judicial consistency. In these circumstances, the Tribunal held that the entire matter should be restored to the Assessing Officer for fresh consideration of all evidences and submissions.

Conclusion: The ex parte appellate order was set aside and the matter was remanded to the Assessing Officer for de novo adjudication after granting reasonable opportunity of hearing.

Ratio Decidendi: Where an appellate order is passed ex parte without considering a bona fide request for time or the material already placed on record, the order may be set aside and the matter remanded to ensure compliance with natural justice and meaningful adjudication on merits.

Issues: Whether the assessee was entitled to the concessional tax rate under section 115BAA of the Income-tax Act, 1961 despite filing Form 10-IC after the due date prescribed under section 139(1) of the Income-tax Act, 1961.

Analysis: The assessee had filed Form 10-IC and disclosed the option for taxation under section 115BAA in the return of income. The form was available on the CPC portal when the return was processed under section 143(1), and no dispute was raised on any other eligibility condition. The delay in filing the form was treated as a procedural lapse, and the processing of the return under the old regime was viewed as a technical error.

Conclusion: The assessee was entitled to the benefit of section 115BAA, and the denial of the concessional rate was not sustained.