VEENABEN ARVINDBHAI SHAH,AHMEDABAD vs. CPC,BENGALURU JURIS. AO-THE ITO, WARD-1(3)(1), PETLAD

ITA 2430/AHD/2025Status: DisposedITAT Ahmedabad16 June 2026AY 2024-257 pages
AI SummaryAllowed

What were the facts?

The assessee claimed a rebate under Section 87A on their total income, which included long-term capital gains taxable under Section 112. The CPC processed the return under Section 143(1) and disallowed the rebate, which was upheld by the CIT(A). The assessee argued that the rebate is applicable to the total income, including special rate incomes, as per the law for AY 2024-25.

What did the Tribunal hold?

The Tribunal held that the assessee is eligible for the rebate under Section 87A for AY 2024-25, even if the income includes tax on long-term capital gains taxable at special rates. The denial by the CPC was based on system logic, not statutory mandate, and the CIT(A)'s interpretation was not in consonance with the law.

What were the issues?

Whether the rebate under Section 87A is admissible on tax on long-term capital gains taxable under Section 112 when the total income does not exceed Rs. 7,00,000/- and the assessee opts for the new tax regime under Section 115BAC(1A).

Which sections of the Income-tax Act were involved?

Section 87A,Section 112,Section 143(1),Section 115BAC(1A)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AHMEDABAD ‘SMC’ BENCH, AHMEDABAD

For Appellant: Shri Girish Parihar, Sr. DR
For Respondent: Shri Girish Parihar, Sr. DR
Hearing: 01.04.2026

PER : SUCHITRA KAMBLE, J M:

The appeal filed by the assessee is against the order passed by the Learned Commissioner of Income Tax (Appeals), ADDL/JCIT(A)[in short “CIT(A)”], Raipur dated 27.11.2025 for the Assessment Year (in short “AY”) 2024-25. 2. The assessee has raised the following grounds of appeal:

“1. The Ld. CIT(A) has erred in law and on facts of the case in upholding prima facie adjustment u/s. 143(1) of the Act made by CPC in respect of rebate claimed u/s. 87A of the Act which is a debatable an

The order continues below.

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