Padmaben Kantilal Ranpara Vs ITO (ITAT Rajkot)
The Income Tax Appellate Tribunal (ITAT), Rajkot allowed the assessee’s appeal against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, dated 26.06.2025, arising from an intimation issued under Section 143(1) of the Income-tax Act, 1961 for Assessment Year (AY) 2024-25. The dispute concerned the denial of rebate under Section 87A amounting to ₹23,653 in respect of Short-Term Capital Gains (STCG) of ₹3,46,992 taxable under Section 111A.
The assessee contended that the tax on STCG under Section 111A, amounting to ₹23,653, qualified for rebate under Section 87A, resulting in nil tax liability. Reliance was placed on the decision of the ITAT Ahmedabad in Jayshreeben Jayantibhai Palsana v. ITO, and it was submitted that the issue stood covered in favour of the assessee. The Department relied on the findings of the CIT(A).
The Tribunal observed that it found no reason to take a different view from that adopted by the Ahmedabad Bench in Jayshreeben Jayantibhai Palsana. The Tribunal reproduced the reasoning in that decision, which identified the core issue as whether a resident individual who opted for taxation under Section 115BAC(1A) and whose total income does not exceed ₹7,00,000 is entitled to rebate under Section 87A against tax payable on STCG under Section 111A in the absence of any express restriction in either Section 87A or Section 111A.
