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The Rajasthan High Court held that the benefit of Section 115BAA could not be denied when Form 10-IC was filed within the period permitted under CBDT Circulars. The Court ruled that procedural delay could not defeat a clearly exercised tax option.
ITAT Delhi held that MAT provisions under Section 115JB cannot apply once a company validly opts for concessional taxation under Section 115BAA. The Tribunal also relied on consistency as the department had accepted the option in earlier years.
ITAT Hyderabad held that CPC cannot make adjustments under Section 143(1)(a) without issuing prior intimation to the assessee as mandated by law. The Tribunal quashed the tax adjustment denying concessional tax benefits because the mandatory opportunity of response was not provided.
The issue was denial of concessional tax regime due to incorrect ITR disclosure and alleged delay in filing Form 10-IC. The Tribunal held that due date depends on the class of assessee, not procedural lapses, and allowed Section 115BAA benefit.
A taxpayer could submit a revised return u/s 139(5) only when it discovered a bona fide omission or incorrect statement in the original return submitted u/s 139(1).
The case addressed whether delayed filing of Form 10-IC invalidates a claim under Section 115BAA. The Tribunal held that the delay was procedural and directed allowance of the concessional tax rate.
The Court held that rejecting condonation solely because the assessment year was not mentioned in the circular is unjustified. It ruled that beneficial circulars must be applied liberally to address genuine hardship.
The new regime offers a concessional 22% tax rate for domestic companies. However, key deductions and depreciation benefits are restricted, requiring careful evaluation.
ITAT Chennai held once the AO has conducted inquiry, examined replies and adopted a legally sustainable view, the same cannot be treated as erroneous. Accordingly, invocation of revisionary jurisdiction under section 263 of the Income Tax Act is not sustainable in law.
The Tribunal held that a minor delay in filing Form 10-IC should not deny concessional tax benefits. It emphasized that substantive compliance prevails over procedural defects.
