METIS FAMILY OFFICE SERVICES PRIVATE LIMITED,CHENNAI, TAMIL NADU vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CORPORATE CIRCLE – 4(1), CHENNAI

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ITA 1922/CHNY/2026Status: DisposedITAT Chennai09 July 2026AY 2020-217 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that a procedural lapse in not filing Form 10-IC electronically within the prescribed time should not deprive the assessee of the substantive benefit under Section 115BAA, especially when the option was exercised in the return and the form was later filed.

What were the facts?

The assessee company claimed a concessional tax regime under Section 115BAA but could not electronically furnish Form 10-IC due to technical glitches. The CPC denied the benefit, and subsequent rectification and first appellate orders upheld this denial.

What were the issues?

Whether the denial of the concessional tax regime benefit due to non-electronic filing of Form 10-IC within the due date is justified, despite technical glitches and subsequent filing.

Which sections of the Income-tax Act were involved?

Section 115BAA,Section 154,Section 143(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘C’ BENCH, CHENNAI

Before: SHRI GEORGE GEORGE K & MS PADMAVATHY S

Hearing: 07.07.2026Pronounced: 09.07.2026

आदेश/ O R D E R PER GEORGE GEORGE K, VICE PRESIDENT: This appeal filed by the assessee is directed against the order of Addl/JCIT(A)-2, Hyderabad dated 09.02.2026 passed under section 250 of the Income Tax Act, 1961 (hereinafter called ‘the Act’). The relevant Assessment Year is 2020-21.

ITA No.1922/CHNY/2026 - 2 - Metis Family Office Services Pvt. Ltd. 2. The solitary issue arising for our consideration in the present appeal is whether the First Appellate Authority (FAA) was justified in confirming the rectification order passed u/s. 154 of the Act, thereby upholding the intimation issued by the CPC u/s.143(1) of the Act, wherein the benefit of the concessional tax regime claimed by the assessee u/s.115BA of the Act was denied on the ground that Form No. 10-IC had not been furnished within the prescribed time.

3.

Brief facts of the case are as follows: The assessee is a private limited company engaged in the business of providing Financial Advisory and Consulting Services. For the assessment year 2020-21, the assessee filed its return of income on 14.02.2021, opting for the concessional tax regime u/s.115BAA of the Act and duly disclosed the said option in ITR-6. However, the assessee could not electronically furnish Form No.10-IC, being the prescribed form for exercising the option u/s.115BAA, due to technical glitches encountered on the Income-tax portal. The return of income was processed by the Centralized Processing Centre (CPC), and an intimation u/s.143(1) of the Act dated 23.12.2021 was issued, computing the tax liability by treating the assessee as governed by the old tax regime and raising a demand of Rs.12,71,970/-. Immediately thereafter, the assessee raised a grievance on the

ITA No.1922/CHNY/2026 - 3 - Metis Family Office Services Pvt. Ltd. Income-tax portal on 12.01.2022, pointing out the issue. However, the said grievance came to be closed without granting the relief sought. Thereafter, the assessee filed an application for rectification u/s.154 of the Act. The CPC, vide order dated 07.06.2024 passed u/s. 154 of the Act, rejected the assessee's claim and confirmed the computation made in the intimation u/s.143(1) by continuing to apply the old tax regime.

4.

Aggrieved by the said rectification order, the assessee preferred an appeal before the FAA. The FAA, however, upheld the rectification order, thereby confirming the denial of the benefit of the concessional tax regime u/s.115BAA of the Act.

5.

The Ld. AR submitted that, at the time of filing the return of income, the assessee could not upload Form No.10-IC due to certain technical issues encountered on the Income-tax portal. Upon receipt of the intimation issued under section 143(1) of the Act, the assessee immediately raised a grievance on the Income-tax portal on 12.01.2022. However, the grievance was closed by the Department stating that the assessee had selected "No" in the column relating to whether it had opted for taxation under sections 115BA/115BAA/115BAB of the Act. The Ld. AR submitted that the

ITA No.1922/CHNY/2026 - 4 - Metis Family Office Services Pvt. Ltd. said observation is factually incorrect, as while filing the return in ITR-6, the assessee had specifically opted for taxation under section 115BA. In support of this contention, the Ld. AR produced a copy of the ITR-6 highlighting the relevant column evidencing the option exercised under section 115BA. The Ld.AR has also filed a physical copy of Form No.10-IC before the Tribunal. It was, therefore, contended that the assessee had unequivocally exercised its option to be governed by the concessional tax regime under section 115BA and that the non-filing of Form No.10-IC electronically was purely on account of technical difficulties. Accordingly, the Ld. AR submitted that the benefit of taxation under section 115BA ought not to be denied on account of a mere procedural lapse. The Ld.AR placed reliance on the order of the Mumbai Bench of the Tribunal in the case of Staubli Tec Systems India Pvt. Ltd. v. DCIT in ITA No.3968/Mum/2024 (order dated 31.10.2025).

6.

The Ld.DR supported the order of the FAA.

7.

We have heard the rival submissions and perused the material available on record. The sole issue for our consideration is whether the assessee is entitled to the benefit of taxation u/s.115BA of the Act despite the non-filing of Form No.10-IC electronically within the

ITA No.1922/CHNY/2026 - 5 - Metis Family Office Services Pvt. Ltd. prescribed time. We find that the assessee has consistently maintained that it had exercised the option for taxation u/s.115BA in the return of income itself and that Form No.10-IC could not be uploaded due to technical issues on the Income-tax portal. The assessee has also placed on record a copy of the ITR-6 evidencing the exercise of the option. The assessee has filed the physical copy of Form No.10-IC before the Tribunal.

8.

On identical facts, we find that the Coordinate Bench of the Mumbai Tribunal in the case of Staubli Tec Systems India Pvt. Ltd. (supra), after considering the decision of the Hon'ble Gujarat High Court in PCIT v. KGY Glass Industries (P.) Ltd., reported in (2023)156 taxman.com 18 (Guj) held that where Form No.10-IC could not be furnished within the prescribed time due to technical or inadvertent reasons, such procedural lapse should not deprive the assessee of the substantive benefit u/s.115BAA of the Act, provided all other statutory conditions are fulfilled. The Coordinate Bench also observed that an appeal is a continuation of the original proceedings and that the Form filed even at the appellate stage can be taken on record for granting the statutory benefit.

ITA No.1922/CHNY/2026 - 6 - Metis Family Office Services Pvt. Ltd. 9. Respectfully following the aforesaid decision of the Coordinate Bench, we are of the considered view that the benefit of the concessional tax regime cannot be denied merely on account of a procedural lapse when the assessee has otherwise exercised the option in the return of income and has subsequently furnished Form No.10-IC. Accordingly, we set aside the orders of the lower authorities on this issue and restore the matter to the file of the AO with a direction to verify the assessee's claim and, if it is found that the assessee has fulfilled all the other conditions prescribed u/s.115BA of the Act, grant the benefit of the concessional tax regime without denying the same merely for delayed or non-electronic filing of Form No.10-IC. The AO shall afford adequate opportunity of being heard to the assessee before passing a fresh order. It is ordered accordingly.

10.

In the result, the appeal filed by the assessee is allowed for allowed for statistical purposes.

Order pronounced in the open court on 9th July,2026 at Chennai.

Sd/- Sd/- (प�मावती एस) (जॉज� जॉज� के) (PADMAVATHY S) (GEORGE GEORGE K) लेखा सद�य/ACCOUNTANT MEMBER उपा�य� /VICE PRESIDENT चे�नई/Chennai, �दनांक/Dated, the 9th July, 2026

ITA No.1922/CHNY/2026 - 7 - Metis Family Office Services Pvt. Ltd.

RSR, Sr.PS

आदेश क� ��त�ल�प अ�े�षत/Copy to: 1. अपीलाथ�/Appellant 2. ��यथ�/Respondent 3. आयकर आयु�त /CIT, Chennai 4. �वभागीय ��त�न�ध/DR 5. गाड� फाईल/GF. By Order Digitally signed by REKHA REKHA SENTHIL RAJ SENTHIL RAJ Date: 2026.07.10 11:39:26 +05'30'

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