Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Rebate under section 87A was held available to a resident individual opting for the new tax regime where total income included long-term capital gains taxable under section 112, because the relevant year's text of section 87A referred to total income without expressly excluding such gains. The Tribunal noted that Parliament had specifically denied rebate for section 112A income, but no comparable bar existed for section 112, so the restriction could not be implied. It also treated the Finance Act, 2025 amendment restricting rebate against special rate income as prospective and substantive, not retrospective. The order denying rebate was set aside and the consequential demand deleted.
Rebate under section 87A was held available to a resident individual opting for the new tax regime where total income included long-term capital gains taxable under section 112, because the relevant year's text of section 87A referred to total income without expressly excluding such gains. The Tribunal noted that Parliament had specifically denied rebate for section 112A income, but no comparable bar existed for section 112, so the restriction could not be implied. It also treated the Finance Act, 2025 amendment restricting rebate against special rate income as prospective and substantive, not retrospective. The order denying rebate was set aside and the consequential demand deleted.
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