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of ITAT held taxpayer eligible for new tax regime under s115BAC despite initially filing return under old regime. Filing Form 10-IE is directory rather than mandatory, provided it is available before AO during assessment. The portal's technical limitations post due date should not restrict taxpayer benefits under the new regime. CBDT Circular permits Form 10-IC/10-IE filing until 31.01.2024 or within 3 months from circular issuance. Since taxpayer's Form 10-IE for AY 2021-22 remained valid and unrevoked during assessment proceedings for AY 2022-23, benefits under new regime were upheld. The benevolent provisions must be interpreted liberally to fulfill legislative intent, not restrictively. Addition deleted accordingly.
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