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Issues: Whether rebate under section 87A of the Income-tax Act, 1961 is allowable against tax payable on short-term capital gains taxable under section 111A of the Income-tax Act, 1961 for an individual assessee opting for section 115BAC of the Income-tax Act, 1961.
Analysis: The assessee's total income was below the threshold for rebate and the denial arose only in relation to tax computed at the special rate on short-term capital gains. The Tribunal noted that consistent co-ordinate bench decisions had held such rebate to be available where the statutory conditions for section 87A were otherwise satisfied, and no contrary binding authority was shown.
Conclusion: The denial of rebate under section 87A on tax payable under section 111A was held to be unsustainable, and the assessee was directed to be granted the rebate.