Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4792
Join Channel
TaxTMI 
