Section 87A rebate under the new tax regime applies to short-term capital gains tax absent express statutory exclusion.

The amended first proviso to section 87A, as applicable from Assessment Year 2024-25, was interpreted to allow rebate to a resident individual assessed under section 115BAC(1A) where total income remains within the prescribed threshold. The analysis noted that neither section 87A nor section 111A contains an express exclusion denying rebate against tax on short-term capital gains, unlike section 112A(6), which specifically restricts the rebate. The later amendment operating from Assessment Year 2026-27 was treated as prospective and not applicable to the year in issue, so rebate under section 87A was available even though the income included short-term capital gains taxable under section 111A.

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Issues: Whether a resident individual opting for the new tax regime and having total income within the statutory threshold is entitled to rebate under section 87A of the Income-tax Act, 1961 against tax payable on short-term capital gains taxable under section 111A for Assessment Year 2024-25.

Analysis: The Tribunal followed the coordinate bench view that the amended first proviso to section 87A applicable from Assessment Year 2024-25 grants rebate to a resident individual whose total income does not exceed the prescribed limit and who is assessed under section 115BAC(1A). It held that neither section 87A nor section 111A contains any express exclusion denying rebate in respect of tax on short-term capital gains, unlike section 112A(6), where the legislature has specifically restricted the rebate. The subsequent amendment introduced from Assessment Year 2026-27 was treated as prospective and not governing the year under appeal.

Conclusion: The assessee was held entitled to rebate under section 87A for Assessment Year 2024-25 even though the income included short-term capital gains taxable under section 111A.

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