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Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
HC determined that online tax filing utilities cannot inherently prevent taxpayers from making legitimate claims under Section 87A of the Income Tax Act. While referencing similar precedents where manual returns were permitted when electronic filing systems were restrictive, the court held that assessees cannot be barred from making statutory claims, whether filing online or manually. The court directed modification of the online utility to allow Section 87A rebate claims for AY 2024-25 and subsequent years, including revised returns under Section 139(5). However, the court clarified that the actual eligibility determination of Section 87A claims remains with tax authorities during return processing, maintaining their statutory authority to examine claim validity.
HC determined that online tax filing utilities cannot inherently prevent taxpayers from making legitimate claims under Section 87A of the Income Tax Act. While referencing similar precedents where manual returns were permitted when electronic filing systems were restrictive, the court held that assessees cannot be barred from making statutory claims, whether filing online or manually. The court directed modification of the online utility to allow Section 87A rebate claims for AY 2024-25 and subsequent years, including revised returns under Section 139(5). However, the court clarified that the actual eligibility determination of Section 87A claims remains with tax authorities during return processing, maintaining their statutory authority to examine claim validity.
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