Section 87A rebate applies to section 111A short-term capital gains absent an express statutory exclusion.

An eligible resident individual taxed under the new regime was entitled to rebate under section 87A where total income did not exceed the prescribed limit, and the rebate could not be denied merely because part of the tax arose on short-term capital gains under section 111A. The statutory text contained no express exclusion for section 111A income, while the legislature had expressly restricted rebate in section 112A(6), showing that exclusions are applied only when stated clearly. A later prospective amendment did not affect the unamended position for the relevant assessment year, so the rebate denial was unsustainable.

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Issues: Whether a resident individual assessed under section 115BAC(1A) and having total income below Rs. 7,00,000 is entitled to rebate under section 87A against tax payable on short-term capital gains chargeable under section 111A.

Analysis: The amended first proviso to section 87A extends rebate to an eligible resident individual under section 115BAC(1A) where total income does not exceed the prescribed limit. The provision does not carve out any exception for income taxable under section 111A. By contrast, the legislature has expressly restricted rebate in section 112A(6), showing that where exclusion was intended it was stated in clear terms. Section 115BAC(1A) governs computation under the new regime and does not itself create a bar to rebate under Chapter VIII. A later prospective amendment cannot control the unamended position for the relevant assessment year, and rebate cannot be denied on the basis of system logic in the absence of an express statutory prohibition.

Conclusion: The assessee was entitled to section 87A rebate against tax on section 111A short-term capital gains for the assessment year in question, and the denial of rebate was unsustainable.

Ratio Decidendi: Where the statute grants section 87A rebate to an eligible assessee under section 115BAC(1A) and contains no express exclusion for section 111A income, rebate cannot be denied merely because the tax liability arises on short-term capital gains.

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