Rajasthan Pulses Private Limited Vs DDIT (ITAT Delhi)
Summary: The Delhi Bench of the Income Tax Appellate Tribunal allowed the appeal of Rajasthan Pulses Private Limited against the order of the learned Addl./JCIT (Appeals), Bhubaneswar dated 07.01.2026 for Assessment Year 2020-21. The dispute concerned the rate of tax applied by the Centralised Processing Centre (CPC), Bengaluru while processing the assessee’s return under section 143(1). The assessee had originally opted for the concessional regime under section 115BAA and paid tax at 22%, but subsequently accepted that it was not eligible for that regime because it had failed to file Form 10-IC within the prescribed time.
The assessee nevertheless contended that denial of section 115BAA did not justify charging tax at 30%. According to the assessee, once it was taxed under the normal provisions, the applicable rate had to be determined with reference to its turnover for FY 2017-18. Since the turnover for FY 2017-18 was only Rs.91.40 crore, below the statutory threshold of Rs.400 crore, the assessee claimed that tax should be charged at 25% rather than 30%.
The CPC rejected the assessee’s rectification application under section 154 and the CIT(A) dismissed the appeal, taking the view that the Act did not confer power upon the CPC or appellate authority to modify the return filed by the assessee. Before the Tribunal, the assessee relied upon the decision of the Mumbai Bench in Bholanath Precision Engineering (P.) Ltd. Vs CIT(A), where a similar issue concerning application of the lower domestic-company tax rate was considered.
