GST payment representations require record-based, reasoned decisions while substantive entitlement remains open for determination by competent authori...
Reassessment sanction under extended limitation required approval from the competent specified authority, invalidating proceedings approved by an inco...
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.
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