2025 (10) TMI 953

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....143(1) of the Income-tax Act, 1961 [hereinafter referred to as "the Act"] dated 11.10.2021. 2. Facts of the Case 2.1 The assessee filed its return of income for A.Y. 2020-21 on 29.09.2020, declaring total income of Rs. 1,13,55,020/-. In the return of income, the assessee had opted for taxation under section 115BAA at the concessional rate of 22%, which was duly reflected in Part A-GEN of ITR-6. The return was processed by the CPC, Bengaluru, under section 143(1) on 11.10.2021. 2.2 While processing the return, the CPC made the following adjustments: Particular As per Return (Rs.) As per 143(1) (Rs.) Difference/Remarks Total Income 1,13,55,020 1,17,95,917 Disallowance u/s 43B of Rs. 4,40,894/- Tax Rate Appl....

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....he CIT(A) dismissed the appeal. 2.6 Aggrieved by the order of CIT(A), the assessee is in appeal before us raising following grounds: 1. The Honourable Commissioner of Income Tax (Appeals) has erred on facts and in law in not giving benefit of taxation at the rate of 22% under section 115BAA. 2. The Honourable Commissioner of Income Tax (Appeals) has erred in not considering the fact that the assessee has opted for taxation under section 115BAA in the Income Tax Return. 3. On facts tax ought to have been calculated at the rate of 22% and the tax as calculated by the appellant in the income tax return ought to have been accepted. 4. The Honourable Commissioner of Income Tax (Appeals) has erred in not giv....

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....ted 11.09.2025, has condoned the delay under section 119(2)(b) and granted permission to file Form No. 10-IC for A.Y. 2020-21. The relevant finding from the PCIT's order reads as under: "Considering the above facts and the report of the AO, the application of the assessee for condonation of delay under section 119(2)(b) of the I.T. Act, 1961 for filing Form No. 10-IC for A.Y. 2020-21 is hereby granted." 4.1 The effect of such condonation is that the assessee's option under section 115BAA stands validly exercised. The denial of concessional rate at 22% under section 115BAA, which formed the sole ground of dispute in the appeal, thus no longer survives. 4.2 In view of the foregoing discussion, and considering that the delay in ....