Appeal against rectification intimation survives on merits; concessional corporate tax rate of 25% applied on qualifying turnover.

A rectification intimation can give rise to an independent cause of action, and an appeal is not barred merely because it challenges the rectification order rather than the original intimation. On the merits, the assessee was not seeking relief under section 115BAA but claimed the general concessional corporate tax rate of 25% on the basis that turnover for the relevant year was below the applicable threshold. The technical rejection was unsustainable, and the tax was directed to be recomputed at 25%.

---

---

Issues: Whether the appeal against the rectification intimation could be rejected on a technical ground, and whether the assessee was entitled to the concessional basic rate of tax of 25% instead of the higher rate applied in computation.

Analysis: The rectification intimation gave rise to an independent cause of action distinct from the original intimation, and both intimations were appealable. The appeal could not be shut out merely because the challenge was directed against the rectification order. On the merits, the assessee was not claiming relief under section 115BAA but was entitled to the general concessional corporate rate of 25% on the basis of the turnover shown for the relevant previous year, which was below the applicable threshold.

Conclusion: The rejection on technical grounds was unsustainable, and the assessee was held entitled to the basic tax rate of 25%. The Assessing Officer was directed to recompute the tax accordingly.

---