Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Rebate under section 87A was held available for Assessment Year 2024-25 to a resident individual opting for the new tax regime, even where total income included short-term capital gains taxed under section 111A. The Tribunal followed a co-ordinate Bench view on identical facts and accepted that, for that year, there was no express statutory bar in section 87A or section 111A denying rebate if the prescribed income threshold was satisfied. The later amendment was treated as prospective, so it did not apply to the year in question. Accordingly, the processing adjustment denying the rebate was deleted and the rebate claim was allowed.
Rebate under section 87A was held available for Assessment Year 2024-25 to a resident individual opting for the new tax regime, even where total income included short-term capital gains taxed under section 111A. The Tribunal followed a co-ordinate Bench view on identical facts and accepted that, for that year, there was no express statutory bar in section 87A or section 111A denying rebate if the prescribed income threshold was satisfied. The later amendment was treated as prospective, so it did not apply to the year in question. Accordingly, the processing adjustment denying the rebate was deleted and the rebate claim was allowed.
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