The Assessee is a private limited company that exercised the 22% tax option under Sec. 115BAA in ITR-6 but inadvertently failed to e-file Form 10-IC by the stipulated date; it sought condonation of delay under Sec. 119(2)(b) after filing the form belatedly. The contention of the Assessee was that it had opted for S. 115BAA in the return and the non-filing of Form 10-IC on time was a bona fide Chartered Accountant error; CBDT Circular No. 6/2022 reflects a liberal intent to avoid genuine hardship, so delay should be condoned and Form 10-IC treated appropriately to allow the 22% rate. The Revenue, however, held the view that Sec. 115BAA (5) mandates filing Form 10-IC in the prescribed manner by the due date under Sec. 139(1), and reliance was placed on Principal Commissioner of Income Tax v. Wipro Limited [2022] 140 taxmann.com 223 (SC) to argue that belated compliance was not permissible. PCIT rejected condonation under Sec. 119(2)(b), citing the lack of power in view of CBDT Circular No. 6/2022.  On writ the Hon’ble Gujarat High Court allowed the petition; directed that the Assessee be permitted to obtain/submit a fresh Form 10-IC and that the authority consider condonation under S. 119(2)(b) in light of the Court’s observations, recognizing S. 115BAA as a relief provision and S. 119(2)(b) as a hardship redressal tool. (AY. 2020-21)