Tax Rate Election Missed: No Retroactive Relief Allowed Under Section 115BAA for Explicit Non-Selection

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....HC held that the petitioner failed to exercise the option for lower taxation under Section 115BAA before the prescribed due date for income tax return. Despite extended filing timelines due to COVID-19, the petitioner explicitly indicated "none of above" when asked about opting for the lower tax rate. The court rejected arguments about inadvertent non-selection and found that the CBDT Circular 6/2022 did not apply, as the petitioner did not satisfy the condition of opting for lower taxation in the return. Consequently, the petitioner was not eligible for the beneficial tax treatment under Section 115BAA for the assessment year 2020-21.....