ITAT Mumbai ruled that the amended first proviso to Section 87A refers to total income and does not distinguish between normal income and STCG taxable under Section 111A. The rebate was therefore held to be available.
ITAT Chennai held that inclusion of taxable long-term capital gains in total income does not disentitle an assessee from claiming Section 87A rebate for AY 2024-25. The Assessing Officer was directed to grant the rebate and recompute the tax liability.
ITAT Rajkot held that Section 87A does not expressly prohibit rebate on tax payable on short-term capital gains under Section 111A for AY 2024-25. Following an earlier Coordinate Bench ruling, the Tribunal allowed the assessee’s appeal.
ITAT Agra held that neither Section 87A nor Section 111A expressly prohibits rebate on tax payable on short-term capital gains for AY 2024-25. The Assessing Officer was directed to grant the rebate.
ITAT Allahabad held that estimating gross profit solely on the basis of the subsequent years GP rate is not justified after rejection of books. It directed estimation based on the average of preceding and succeeding years’ accepted trading results.
The ITAT Pune held that detailed agreements, invoices and supporting records established that management support services were actually rendered by the Associated Enterprise. It ruled that the payment was at arm’s length and deleted the entire transfer pricing adjustment.
ITAT excluded EDCIL, Just Dial, Info Edge and India Exposition Mart as transfer pricing comparables due to functional differences and restored one comparable for verification.
ITAT held interest on government grant funds was not taxable as the MOU required it to be added to the project corpus.
The ITAT Ahmedabad held that royalty payments should continue to be benchmarked under TNMM by following earlier decisions in the assessees own case. It found no reason to replace TNMM with CUP where identical facts had already been decided. The Department’s transfer pricing challenge was therefore dismissed.
ITAT upheld taxation of IPS and CEV subsidies following the Section 2(24) amendment, while partly allowing the appeal on other issues.
