Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
For AY 2025-26, the section 87A rebate applied to income-tax computed on total income within the prescribed threshold, without excluding tax on short-term capital gains taxable under section 111A. Section 111A prescribed the applicable tax rate but did not bar the rebate. A subsequent restriction limiting rebate to tax computed under the concessional tax regime applied only from AY 2026-27 and could not operate retrospectively. Administrative circulars and procedural utilities cannot impose a substantive statutory restriction. Excluding tax attributable to eligible short-term capital gains from the rebate was therefore unsustainable, requiring recomputation and full rebate subject to verification of remaining eligibility conditions.
For AY 2025-26, the section 87A rebate applied to income-tax computed on total income within the prescribed threshold, without excluding tax on short-term capital gains taxable under section 111A. Section 111A prescribed the applicable tax rate but did not bar the rebate. A subsequent restriction limiting rebate to tax computed under the concessional tax regime applied only from AY 2026-27 and could not operate retrospectively. Administrative circulars and procedural utilities cannot impose a substantive statutory restriction. Excluding tax attributable to eligible short-term capital gains from the rebate was therefore unsustainable, requiring recomputation and full rebate subject to verification of remaining eligibility conditions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
