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...
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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