The assessee sought condonation of delay in filing Form No. 10-IC for availing concessional tax rate under section 115BAA, which was rejected by the Principal CIT adopting a strict and technical approach. The High Court held that section 119(2)(b) confers discretionary power upon authorities to mitigate genuine hardship and must be construed as a beneficial provision. The assessee demonstrated genuine hardship arising from successive family deaths of the person handling its tax matters, which directly affected timely statutory compliance. The Court observed that when substantial justice and technical considerations conflict, preference must be given to substantial justice, particularly where the assessee’s intention to opt for section 115BAA was evident from the return of income and audit report. It was further held that filing of Form 10-IC prior to filing of return is not mandatory and procedural delay should not deprive an assessee of a substantive statutory benefit if genuine hardship is established. The rejection of condonation was therefore held to be arbitrary and contrary to the remedial intent of section 119(2)(b). Accordingly, the order was quashed and the respondent authority was directed to condone the delay, accept Form 10-IC and grant consequential relief by recomputing tax liability. Relied  on B.M. Malani v. CIT (2008) 219 CTR 313  (SC) (AY. 2021-22).