Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Resident individual opting for the new tax regime was entitled to rebate despite part of the tax liability arising from short-term capital gains taxed at the special rate. The Tribunal followed its consistent view that, where total income is below the statutory rebate threshold, rebate relief is available even against tax on short-term capital gains under section 111A. In the absence of any contrary authority or distinguishing facts, the denial of rebate was held to be contrary to law and was reversed.
Resident individual opting for the new tax regime was entitled to rebate despite part of the tax liability arising from short-term capital gains taxed at the special rate. The Tribunal followed its consistent view that, where total income is below the statutory rebate threshold, rebate relief is available even against tax on short-term capital gains under section 111A. In the absence of any contrary authority or distinguishing facts, the denial of rebate was held to be contrary to law and was reversed.
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