Appeal allowed; impugned order quashed as regulator failed to prove nexus or manipulative scheme; sale genuine - s.12A(a)-(c), Regs 3(a)-(d),4(1),4(2)...
Appellant's ring-back tone service held OIDAR, taxable domestically for 01.07.2012-31.07.2016; liability confirmed, penalties vacated, remanded for re...
ITAT held that the assessee, being a domestic company which elected taxation under section 115BAA by filing Form 10IC for FY 2019-20 and subsequent years, is taxable at the prescribed flat rate of 22% on its total income, including long-term capital gains. The Tribunal found no merit in applying the concessional 20% rate under section 112 and upheld the order of the CIT(A). Consequentially, the appeal is dismissed and the assessment stands confirmed at the 22% rate pursuant to the assessee's valid exercise of the 115BAA option.
ITAT held that the assessee, being a domestic company which elected taxation under section 115BAA by filing Form 10IC for FY 2019-20 and subsequent years, is taxable at the prescribed flat rate of 22% on its total income, including long-term capital gains. The Tribunal found no merit in applying the concessional 20% rate under section 112 and upheld the order of the CIT(A). Consequentially, the appeal is dismissed and the assessment stands confirmed at the 22% rate pursuant to the assessee's valid exercise of the 115BAA option.
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