Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
For AY 2024-25, the notes state that section 87A contained no express exclusion for tax on short-term capital gains taxable under section 111A where a resident individual is governed by section 115BAC(1A). The express statutory restriction applicable to long-term capital gains under section 112A could not be extended to short-term capital gains. The Finance Act 2025 amendment limiting the rebate to tax computed under section 115BAC(1A), effective from AY 2026-27, is described as prospective; therefore, it does not restrict the rebate under the earlier law. The stated effect is that eligible taxpayers may claim section 87A rebate against such short-term capital gains tax for AY 2024-25.
For AY 2024-25, the notes state that section 87A contained no express exclusion for tax on short-term capital gains taxable under section 111A where a resident individual is governed by section 115BAC(1A). The express statutory restriction applicable to long-term capital gains under section 112A could not be extended to short-term capital gains. The Finance Act 2025 amendment limiting the rebate to tax computed under section 115BAC(1A), effective from AY 2026-27, is described as prospective; therefore, it does not restrict the rebate under the earlier law. The stated effect is that eligible taxpayers may claim section 87A rebate against such short-term capital gains tax for AY 2024-25.
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