Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
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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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