https://www.taxtmi.com/caselaws?id=465790 Denial of concessional tax under s. 115BAA solely due to non-filing of Form 10-IC electronically within the timeline under r. 21AE was held unsustainable. The ITAT found that procedural lapses should not defeat substantive statutory entitlements where bona fide intent and compliance are evident, relying on the principle of fair tax administration and CBDT Circular No. 14 requiring assessing officers to facilitate lawful relief. Since the taxpayer had consistently and unambiguously manifested the option for s. 115BAA in the return, computation and audit report, and the Revenue did not dispute substantive eligibility, the benefit could not be denied for mere procedural non-filing. The appeal was allowed and concessional taxation under s. 115BAA was granted. en-us Tue, 22 Jul 2025 00:00:00 +0530 Thu, 08 Jan 2026 11:00:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465790 Denial of concessional tax under s. 115BAA solely due to non-filing of Form 10-IC electronically within the timeline under r. 21AE was held unsustainable. The ITAT found that procedural lapses should not defeat substantive statutory entitlements where bona fide intent and compliance are evident, relying on the principle of fair tax administration and CBDT Circular No. 14 requiring assessing officers to facilitate lawful relief. Since the taxpayer had consistently and unambiguously manifested the option for s. 115BAA in the return, computation and audit report, and the Revenue did not dispute substantive eligibility, the benefit could not be denied for mere procedural non-filing. The appeal was allowed and concessional taxation under s. 115BAA was granted. Case-Laws Income Tax Tue, 22 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465790