SATARA ENGINEERING PROJECTS AND EQUIPMENTS PRIVATE LIMITED,SATARA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE, SATARA, SATARA

ITA 2450/PUN/2025Status: DisposedITAT Pune06 January 2026AY 2024-25Bench: OR at the time of hearing."12 pages
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What did the Tribunal hold?

The Tribunal held that once the option under Section 115BAB is exercised and accepted for the first year, it continues to apply for subsequent assessment years. The CPC erred in not applying the concessional rate without proper adjudication.

What were the facts?

The assessee company opted for the concessional tax rate under Section 115BAB for AY 2023-24, which was accepted. For AY 2024-25, the CPC processed the return at a higher rate (22% under Section 115BAA) instead of the concessional rate (15% under Section 115BAB), despite the option being valid for subsequent years.

What were the issues?

Whether the concessional tax rate under Section 115BAB, once exercised, automatically applies to subsequent assessment years without a fresh option, and if the CPC can arbitrarily change the tax rate during processing.

Which sections of the Income-tax Act were involved?

Section 115BAB,Section 115BAA,Section 139(1)

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Cases cited in this judgment(2)Show list

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Income Tax Appellate Tribunal, PUNE BENCHES “B”, PUNE

Before: DR.MANISH BORAD & SHRI VINAY BHAMORE

For Appellant: Shri Ashwani Kumar &
For Respondent: Shri Ganesh B. Budruk
Hearing: 18.12.2025Pronounced: 06.01.2026

PER DR. MANISH BOARD, ACCOUNTANT MEMBER :

The captioned appeal at the instance of assessee pertaining to A.Y. 2024-25 is directed against the order dated 25.08.2025 framed by ld. Addl/JCIT(A)-1, Ahmedabad arising out of Intimation order dated 04.03.2025 passed u/s.143(1) of the Income Tax Act, 1961 (in short ‘the Act’).

2.

Assessee has raised following grounds of appeal :

“1. That order passed u/s 250 by the Learned Additional Commissioner of Income Tax (Appeals)-1, Ahmedabad is against law and facts on the file in as much as Learned Additional CIT(A) was not justified to uphold the action of Centralized Processing Ce

The order continues below.

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