Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
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Section 87A, as applicable for the relevant assessment year, did not exclude tax on short-term capital gains taxable under section 111A. Although section 112A expressly limits the rebate for specified long-term capital gains, no equivalent restriction applied to section 111A income; the special tax rate governs tax computation but does not curtail the independent rebate absent express legislation. A later amendment restricting the rebate to tax computed under section 115BAC(1A), effective from Assessment Year 2026-27, cannot deny the benefit for Assessment Year 2024-25 without express retrospective operation. The notes state that rebate was to be granted and tax recomputed accordingly.
Section 87A, as applicable for the relevant assessment year, did not exclude tax on short-term capital gains taxable under section 111A. Although section 112A expressly limits the rebate for specified long-term capital gains, no equivalent restriction applied to section 111A income; the special tax rate governs tax computation but does not curtail the independent rebate absent express legislation. A later amendment restricting the rebate to tax computed under section 115BAC(1A), effective from Assessment Year 2026-27, cannot deny the benefit for Assessment Year 2024-25 without express retrospective operation. The notes state that rebate was to be granted and tax recomputed accordingly.
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