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ITAT Delhi rules that mere delay in filing Form 10-IC does not invalidate the concessional tax rate under Section 115BAA if the assessee’s eligibility and intent are established. The ruling reinforces that procedural lapses cannot override substantive rights when compliance is otherwise demonstrable.
The ITAT Delhi has ruled that a late filing of Form 10-IC under Section 115BAA does not automatically disqualify a company from the 22% concessional tax rate, provided the intent to opt in is evident and eligibility is not in dispute. This sets a critical precedent for businesses facing administrative delays, affirming that substance overrides mere procedural non-compliance in direct tax matters.
ITAT Mumbai rules that a delay in filing Form 10-IC under Section 115BAA does not bar a taxpayer from claiming concessional tax benefits, provided the intent to opt for the regime and compliance with statutory conditions are established. This decision underscores substance over procedural formalities, offering relief to taxpayers facing similar technical lapses.
ITAT Delhi rules that assessees can claim the 22% concessional tax rate under Section 115BAA even if Form 10-IC is filed late, provided substantial compliance and intent are proven. The decision underscores a beneficial interpretation, protecting taxpayers from technical disqualifications due to procedural lapses.