Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
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.
Note: It is a system-generated summary and is for quick reference only.