Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Eligibility for rebate under section 87A was contested for tax components including shortterm capital gains taxed at special rates, longterm capital gains, and tax on transfer of virtual digital assets. The tribunal found that the statutory language and existing precedents permit rebate against tax on shortterm capital gains taxed under the special rate provision, and directed allowance of the rebate (Rs. 13,320) with recomputation of tax. The tribunal rejected the claim for rebate against tax on income from transfer of virtual digital assets, leaving that element unaffected. The assessee had opted for the new tax regime; a prospective legislative amendment clarified intent but did not alter the outcome for the year in question.
Eligibility for rebate under section 87A was contested for tax components including shortterm capital gains taxed at special rates, longterm capital gains, and tax on transfer of virtual digital assets. The tribunal found that the statutory language and existing precedents permit rebate against tax on shortterm capital gains taxed under the special rate provision, and directed allowance of the rebate (Rs. 13,320) with recomputation of tax. The tribunal rejected the claim for rebate against tax on income from transfer of virtual digital assets, leaving that element unaffected. The assessee had opted for the new tax regime; a prospective legislative amendment clarified intent but did not alter the outcome for the year in question.
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