Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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.
Note: It is a system-generated summary and is for quick reference only.