SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Section 87A rebate was treated, for the pre-restriction period discussed, as available against income-tax on total income, including tax on short-term capital gains subject to special-rate taxation, where a resident individual met the new-regime eligibility conditions. The distinction between special-rate computation and rebate availability was central: the special-rate provision determined tax on qualifying gains but contained no express rebate exclusion. By contrast, the express exclusion for specified long-term capital gains supported the view that a similar restriction could not be implied for short-term gains. Later statutory language limiting the rebate was prospective and requires separate assessment where applicable.
Section 87A rebate was treated, for the pre-restriction period discussed, as available against income-tax on total income, including tax on short-term capital gains subject to special-rate taxation, where a resident individual met the new-regime eligibility conditions. The distinction between special-rate computation and rebate availability was central: the special-rate provision determined tax on qualifying gains but contained no express rebate exclusion. By contrast, the express exclusion for specified long-term capital gains supported the view that a similar restriction could not be implied for short-term gains. Later statutory language limiting the rebate was prospective and requires separate assessment where applicable.
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