Procedural delay in Form 10-IC filing cannot deny section 115BAA concessional tax benefit when substantive eligibility is met.

Delay in filing Form 10-IC was treated as a procedural lapse that could not defeat the concessional regime under section 115BAA where the assessee had already opted for the regime in the return of income and otherwise met the substantive conditions. The Tribunal applied beneficial interpretation and followed coordinate bench rulings to hold that procedural non-compliance should not deny a statutory benefit when eligibility is undisputed. The delay was treated as a curable irregularity, and the assessee was entitled to section 115BAA relief; denial of concessional taxation solely because the form was filed late was unsustainable.

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Issues: Whether delay in filing Form 10-IC could justify denial of the concessional tax regime under section 115BAA despite the assessee having opted for the regime in the return of income and otherwise satisfying the substantive conditions.

Analysis: The assessee had reflected its choice under section 115BAA in the return, and the controversy arose only because the prescribed form was filed belatedly. The Tribunal followed coordinate bench decisions holding that the filing of the form is a procedural requirement and that procedural non-compliance should not defeat a substantive statutory benefit when the assessee's eligibility is otherwise undisputed. Applying the principle of beneficial interpretation, the Tribunal treated the delay as a curable irregularity and condoned it.

Conclusion: The assessee was entitled to the benefit of section 115BAA, and the denial of concessional taxation merely on account of delayed filing of Form 10-IC was unsustainable.

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