Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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