Tax authority's substitution of projected figures with actuals overturned; original acquisition valuation upheld; transfer pricing issues remitted for...
Beneficial owner held liable for differential customs duty; royalties added under Rule 10(1)(c); confiscation, penalties under s.111(m), s.114A, s.112...
ITAT allowed the assessee's appeal, holding that the restriction under s.112A(6) on claiming rebate u/s 87A applies only to Long-Term Equity Capital Gains covered by s.112A(1)(ii), and not to Long-Term Debt Capital Gains, which are governed by s.112. As the assessee's tax on debt LTCG and on other normal income each exceeded the rebate threshold of Rs. 25,000, the assessee was held entitled to the full rebate of Rs. 25,000 u/s 87A. CPC was directed to recompute the tax liability accordingly in line with this interpretation.
ITAT allowed the assessee's appeal, holding that the restriction under s.112A(6) on claiming rebate u/s 87A applies only to Long-Term Equity Capital Gains covered by s.112A(1)(ii), and not to Long-Term Debt Capital Gains, which are governed by s.112. As the assessee's tax on debt LTCG and on other normal income each exceeded the rebate threshold of Rs. 25,000, the assessee was held entitled to the full rebate of Rs. 25,000 u/s 87A. CPC was directed to recompute the tax liability accordingly in line with this interpretation.
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