Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
The HC directed the respondents to modify the tax filing system for AY 2024-25 to allow assessees to claim the rebate u/s 87A of the Income Tax Act, 1961. The statutory right to claim rebate cannot be overridden by procedural changes like software utility. The rebate is linked to total income and tax liability, with the onus on tax authorities to ensure proper implementation if statutory criteria are met. Procedural impediments depriving statutory benefits warrant judicial intervention. As interim relief, the CBDT was directed to extend the due date for e-filing returns till 15.01.2025 for assessees required to file by 31.12.2024, ensuring opportunity to exercise statutory rights.
The HC directed the respondents to modify the tax filing system for AY 2024-25 to allow assessees to claim the rebate u/s 87A of the Income Tax Act, 1961. The statutory right to claim rebate cannot be overridden by procedural changes like software utility. The rebate is linked to total income and tax liability, with the onus on tax authorities to ensure proper implementation if statutory criteria are met. Procedural impediments depriving statutory benefits warrant judicial intervention. As interim relief, the CBDT was directed to extend the due date for e-filing returns till 15.01.2025 for assessees required to file by 31.12.2024, ensuring opportunity to exercise statutory rights.
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