Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Bogus-purchase additions are limited to embedded profit where corresponding sales are accepted, while accommodation-entry information can support reas...
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 4884 
