Section 115BAA tax rate applies to opted domestic companies, including long-term capital gains, not the section 112 rate.

A domestic company that exercised the section 115BAA option was treated as taxable at 22% on its income, including long-term capital gains, because the concessional regime governed the company's applicable tax rate once elected. The Tribunal accepted the Revenue's position that section 115BAA displaced the company's plea for a 20% rate under section 112, and the lower rate claim was rejected.

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Issues: Whether a domestic company that had exercised the option under section 115BAA of the Income-tax Act, 1961 was liable to pay tax on its long-term capital gains at 20% under section 112 or at 22% under section 115BAA.

Analysis: The assessee had opted for taxation under section 115BAA for the relevant assessment year. The dispute was confined to the applicable rate on the company's total income, including the long-term capital gains returned by it. The Tribunal accepted the Revenue's position that, once the assessee had opted for section 115BAA, the applicable rate for the company's income was 22%.

Conclusion: The rate of tax under section 115BAA at 22% was held applicable, and the assessee's plea for taxation at 20% under section 112 was rejected.

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