Section 87A rebate covers short-term capital gains tax under the new regime for eligible Assessment Year 2024-25 taxpayers.

For Assessment Year 2024-25, a resident individual taxed under the new tax regime may claim the Section 87A rebate against tax liability including short-term capital gains taxable under Section 111A, provided total income is within the prescribed threshold. Section 87A contained no express exclusion for such gains, unlike the specific limitation applicable to certain long-term capital gains under Section 112A. Section 115BAC(1A) governs tax computation but does not displace the separate rebate. A later restriction effective from Assessment Year 2026-27 applies prospectively and does not affect the unamended position for Assessment Year 2024-25.

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Issues: Whether, for Assessment Year 2024-25, a resident individual taxable under Section 115BAC(1A) of the Income-tax Act, 1961 and having total income within the prescribed threshold can claim rebate under Section 87A against tax on short-term capital gains chargeable under Section 111A of the Income-tax Act, 1961.

Analysis: Section 87A, as applicable to the relevant assessment year, contained no express exclusion of tax payable on short-term capital gains under Section 111A. Although Section 112A(6) expressly limits the rebate in relation to specified long-term capital gains, no corresponding restriction occurs in Section 111A. A restriction consciously enacted in one analogous provision cannot be imported into another provision where the Legislature omitted it. Section 115BAC(1A) governs tax computation under the new regime and does not displace the independent rebate under Section 87A. The subsequent restriction introduced with effect from Assessment Year 2026-27 is prospective and cannot curtail the benefit available under the unamended law for Assessment Year 2024-25.

Conclusion: The assessee is entitled to rebate under Section 87A against tax liability including short-term capital gains taxable under Section 111A for Assessment Year 2024-25.

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