Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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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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