The HC allowed the assessee's appeal, directing the respondent...

The HC allowed the assessee's appeal, directing the respondent to condone the delay in filing Form 10IC and accept it as valid for the relevant Assessment Year. The petitioner had exercised the option under Section 115BAA by filing the return under Section 139(1) with tax computed at 22%, supported by intimation under Section 143. The failure to timely file Form 10IC, as prescribed by Rule 21AE, was due to technical issues, for which CBDT issued Circular No. 6/22 allowing late filing. The Court held that Section 119(2)(b) empowers the respondent to condone delay to mitigate hardship and ensure substantive compliance. Consequently, the petitioner is entitled to concessional tax rate benefits under Section 115BAA, and the respondent's rejection of the application on grounds of lack of power was set aside.