The ITAT allowed the appeal, holding that the resident individual assessee, having opted for taxation under section 115BAC(1A) and whose total income for AY 2024-25 did not exceed Rs. 7,00,000, is entitled to rebate under section 87A. It held that neither section 87A nor section 111A contains any express prohibition against allowing rebate on tax payable on STCG taxable under section 111A. The Tribunal noted that denial of rebate by CPC, Bengaluru, was based on system-driven logic without statutory backing. The proposed prospective amendment in Finance Bill 2025 was treated as clarificatory of prior legislative intent.
The ITAT allowed the appeal, holding that the resident individual assessee, having opted for taxation under section 115BAC(1A) and whose total income for AY 2024-25 did not exceed Rs. 7,00,000, is entitled to rebate under section 87A. It held that neither section 87A nor section 111A contains any express prohibition against allowing rebate on tax payable on STCG taxable under section 111A. The Tribunal noted that denial of rebate by CPC, Bengaluru, was based on system-driven logic without statutory backing. The proposed prospective amendment in Finance Bill 2025 was treated as clarificatory of prior legislative intent.
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