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of ITAT allowed the appeal and directed recognition of the assessee's entitlement to tax at the concessional rate under s.115BAA despite belated filing of Form 10-IC and delayed return. The Tribunal found substantial compliance: the assessee unequivocally exercised the s.115BAA option in the return and Form 3CA, computed and discharged tax at 22%, and the procedural lapse in e-filing arose from bona fide delay caused by a search and finalisation of accounts. Applying the principle of beneficial interpretation, the Tribunal held that a procedural default in filing Form 10-IC should not defeat the substantive fiscal benefit, and ordered allowance of the concession.
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