Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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Section 87A rebate was held available to a resident individual on tax attributable to short-term capital gains for AY 2024-25, because the provision then in force contained no express exclusion for special-rate income and a denial could not be implied. The Tribunal noted that the legislature had excluded certain capital gains expressly elsewhere, but had not done so for this category of income. The Finance Act, 2025 amendment excluding special-rate income was treated as prospective from AY 2026-27, so the assessee's rebate claim for the year in question was allowed and the assessment was to be recomputed accordingly.
Section 87A rebate was held available to a resident individual on tax attributable to short-term capital gains for AY 2024-25, because the provision then in force contained no express exclusion for special-rate income and a denial could not be implied. The Tribunal noted that the legislature had excluded certain capital gains expressly elsewhere, but had not done so for this category of income. The Finance Act, 2025 amendment excluding special-rate income was treated as prospective from AY 2026-27, so the assessee's rebate claim for the year in question was allowed and the assessment was to be recomputed accordingly.
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