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...
For Assessment Year 2025-26, Section 87A rebate under the new tax regime applied to an eligible assessee's entire tax liability, including tax on short-term capital gains taxable at the special rate under Section 111A, because the provision then contained no exclusion for such income. A later restriction on rebate for special-rate income, effective from Assessment Year 2026-27, did not apply. Denial of the rebate during return processing without prior intimation or an opportunity of hearing also contravened the prescribed procedure. The Tribunal deleted the adjustment and directed grant of the claimed rebate.
For Assessment Year 2025-26, Section 87A rebate under the new tax regime applied to an eligible assessee's entire tax liability, including tax on short-term capital gains taxable at the special rate under Section 111A, because the provision then contained no exclusion for such income. A later restriction on rebate for special-rate income, effective from Assessment Year 2026-27, did not apply. Denial of the rebate during return processing without prior intimation or an opportunity of hearing also contravened the prescribed procedure. The Tribunal deleted the adjustment and directed grant of the claimed rebate.
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