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The ITAT allowed the appeal, holding that the assessee validly exercised the option for taxation under section 115BAA for AY 2020-21, as evidenced by declarations in the ITR-6 and tax audit report. The non-filing of Form No. 10-IC within the prescribed time under Rule 21AE was deemed a procedural lapse that did not vitiate substantive compliance. The assessee's omission was involuntary, given the absence of intimation under section 143(1) and the expiry of the filing window before awareness of the demand. The matter was restored to the AO for verification of factual matrix and fulfillment of all conditions under section 115BAA. The assessee was directed to file Form No. 10-IC during AO proceedings. The appeal was allowed for statistical purposes, affirming that procedural defects alone cannot defeat a bona fide claim where revenue is not prejudiced.
The ITAT allowed the appeal, holding that the assessee validly exercised the option for taxation under section 115BAA for AY 2020-21, as evidenced by declarations in the ITR-6 and tax audit report. The non-filing of Form No. 10-IC within the prescribed time under Rule 21AE was deemed a procedural lapse that did not vitiate substantive compliance. The assessee's omission was involuntary, given the absence of intimation under section 143(1) and the expiry of the filing window before awareness of the demand. The matter was restored to the AO for verification of factual matrix and fulfillment of all conditions under section 115BAA. The assessee was directed to file Form No. 10-IC during AO proceedings. The appeal was allowed for statistical purposes, affirming that procedural defects alone cannot defeat a bona fide claim where revenue is not prejudiced.
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