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Case Law Details

Case Name : Concentrix Daksh Services India Pvt. Ltd. Vs ACIT (ITAT Delhi)
Appeal Number : ITA No. 2552/Del/2023
Date of Judgement/Order : 20/09/2023
Related Assessment Year : 2021-22
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Concentrix Daksh Services India Pvt. Ltd. Vs ACIT (ITAT Delhi)

Form 10IC is required to be filed only in the first year wherein concessional rate of taxes was opted for the first time by an assessee and Concessional rate of tax under section 115BAA of the Income-tax Act, 1961 cannot be denied on the ground that assessee had not filed fresh form 10IC

Introduction: The Concentrix Daksh Services India Pvt. Ltd. vs. ACIT case, heard by the Income Tax Appellate Tribunal (ITAT) Delhi, raises a significant question regarding the application of concessional tax rates under section 115BAA of the Income-tax Act, 1961.

Detailed Analysis: In this case, Concentrix Daksh Services India Pvt. Ltd., a resident corporate entity engaged in Information Technology Enabled Services (ITES), filed its tax return for the assessment year 2021-22, opting for the concessional rate of tax provided under section 115BAA. The Centralized Processing Centre (CPC) processed their return and denied the benefit of concessional tax rates under section 115BAA.

The crux of the issue lay in the fact that the assessee had not filed a fresh Form 10IC for the assessment year in question, leading to the denial of the concessional rate of tax by both the CPC and the first appellate authority.

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