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ITAT allowed the appeal of the anonymous assessee, holding that s.87A does not expressly exclude long-term capital gains taxed at special rates from the rebate; therefore the statutory text confers an unambiguous entitlement and must be applied. The Tribunal observed the first proviso to s.87A refers only to total income under s.115BAC(1A) and that the Finance Act, 2024 amendment effective 01.04.2025 does not affect AY 2024-25. Consequently, for the relevant assessment year the assessee is entitled to claim rebate under s.87A and the CPC's denial is set aside.
ITAT allowed the appeal of the anonymous assessee, holding that s.87A does not expressly exclude long-term capital gains taxed at special rates from the rebate; therefore the statutory text confers an unambiguous entitlement and must be applied. The Tribunal observed the first proviso to s.87A refers only to total income under s.115BAC(1A) and that the Finance Act, 2024 amendment effective 01.04.2025 does not affect AY 2024-25. Consequently, for the relevant assessment year the assessee is entitled to claim rebate under s.87A and the CPC's denial is set aside.
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