Section 10A and related deductions: Tribunal rejects separate-undertaking claim, but allows loss set-off, ESOP cost and foreign tax credit in principl...
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The Tribunal applied the doctrine of substantial compliance and beneficial interpretation where the assessee clearly exercised the option for the concessional tax regime and paid tax at that rate, but Form 10-IC upload failed due to an ITBA portal glitch and staff error; treating the filing of Form 10-IC as directory rather than mandatory, the Tribunal held that denial of relief solely for late filing was inappropriate and directed the assessing officer to compute tax under section 115BAA for A.Y. 2024-25, with interest-related contention treated as consequential.
The Tribunal applied the doctrine of substantial compliance and beneficial interpretation where the assessee clearly exercised the option for the concessional tax regime and paid tax at that rate, but Form 10-IC upload failed due to an ITBA portal glitch and staff error; treating the filing of Form 10-IC as directory rather than mandatory, the Tribunal held that denial of relief solely for late filing was inappropriate and directed the assessing officer to compute tax under section 115BAA for A.Y. 2024-25, with interest-related contention treated as consequential.
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