MINA MANOJ AGRAWAL,VADODARA vs. THE INCOME TAX OFFICER, WARD 3(1)(1), VADODARA

ITA 470/AHD/2026Status: DisposedITAT Ahmedabad18 September 2026AY 2021-2210 pages
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What were the facts?

The assessee filed returns under the old tax regime and later opted for the new tax regime by filing Form 10-IE belatedly for AY 2021-22. For AY 2022-23 and 2023-24, the assessee contended that the earlier Form 10-IE filing was sufficient for opting into the new tax regime for subsequent years.

What did the Tribunal hold?

For AY 2021-22, the tribunal held that while the new tax regime option was invalid due to belated filing, the assessee was entitled to Chapter VI-A deductions under the old tax regime. For AY 2022-23 and 2023-24, the tribunal held that filing Form 10-IE once is sufficient for subsequent years, and the returns should be treated under the new tax regime.

What were the issues?

Whether the belated filing of Form 10-IE for AY 2021-22 invalidates the new tax regime option and if Chapter VI-A deductions are allowable. Whether a single filing of Form 10-IE is sufficient for subsequent assessment years under the new tax regime.

Which sections of the Income-tax Act were involved?

Section 115BAC,Section 139,Section 250

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Heard together (3 matters)

ITA 470/AHD/2026
ITA 471/AHD/2026
ITA 472/AHD/2026

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आयकर अपील"य अ"धकरण, अहमदाबाद पीठ", अहमदाबाद INCOME TAX APPELLATE TRIBUNAL, AHMEDABAD BENCHES, AHMEDABAD BENCH: SMC

BEFORE SHRI NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER AND SHRI SANJAY KUMAR, JUDICIAL MEMBER

1.

ITA 470/AHD/2026 (िनधा"रण वष"/Assessment Year: 2021-22) Mina Manoj Agrawal ITO Ward 3(1)(1) Mina Manoj Agrawal, A-14, Vadodara-390007, Vadodara-390019, Gujarat अपीलाथ" Appellant ""थ" Respondent PAN of Assessee: ANGPA3828F

अपीलाथ" "ारा/Appellant represented by: Shri Manan Agarwal, AR ""थ" "ारा/Respondent represented by: Shri Rakesh Rathi, Sr. Dr.

2.

ITA 471/AHD/2026 (िनधा"रण वष"/Assessment Year: 2022-23) Mina Manoj Agrawal] ITO Ward 3(1)(1) Mina Manoj Agrawal, A-14, Vadodara-390007, Vadodara-390019, Gujarat अपीलाथ" Appellant ""थ" Respondent PAN of Assessee: ANGPA3828F

अपीलाथ" "ारा/Appellant represented by: Shri Manan Agarwal, AR ""थ" "ारा/Respondent represented by: Shri Rakesh Rathi, Sr. Dr.

3.

ITA 472/AHD/2026 (िनधा"रण वष"/Assessment Year: 2023-24) Mina Manoj Agrawal] Vs. ITO

ITA 470, 471, 472/AHD/2026 AY- 2021-22, 2022-23, 2023-24

The order continues below.

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