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    <title>2024 (11) TMI 1409 - ITAT KOLKATA</title>
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    <description>The Tribunal ruled that the failure to file Form No. 10IE by the due date, a procedural lapse, did not disqualify the assessee from availing the concessional tax rate under Section 115BAC, as it did not result in any revenue loss. The Tribunal emphasized substantial justice over technical compliance and directed the Assessing Officer to grant the concessional tax rate benefit, subject to verification of other conditions under Section 115BAC. The delay in filing the appeal before the CIT(A) was deemed secondary, as the primary issue was resolved in favor of the assessee. Appeals were allowed for statistical purposes.</description>
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      <title>2024 (11) TMI 1409 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=460050</link>
      <description>The Tribunal ruled that the failure to file Form No. 10IE by the due date, a procedural lapse, did not disqualify the assessee from availing the concessional tax rate under Section 115BAC, as it did not result in any revenue loss. The Tribunal emphasized substantial justice over technical compliance and directed the Assessing Officer to grant the concessional tax rate benefit, subject to verification of other conditions under Section 115BAC. The delay in filing the appeal before the CIT(A) was deemed secondary, as the primary issue was resolved in favor of the assessee. Appeals were allowed for statistical purposes.</description>
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