PRAFULCHANDRA NANALAL KOTECHA,RAJKOT vs. INCOME TAX OFFICER , RAJKOT

ITA 817/RJT/2025Status: DisposedITAT Rajkot22 April 2026AY 2024-257 pages
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What were the facts?

The assessee claimed a rebate under Section 87A of the Income Tax Act, 1961, for AY 2024-25. The Assessing Officer (CPC) and the CIT(A) denied this rebate, citing it was not available on income taxed at special rates, including short-term capital gains (STCG) under Section 111A.

What did the Tribunal hold?

The Tribunal held that while the rebate under Section 87A is head-neutral, it is rate-sensitive and not applicable to tax computed under special rate provisions, particularly capital gains. Therefore, the rebate is admissible only on the normal income portion.

What were the issues?

Whether the rebate under Section 87A is available on short-term capital gains taxed at special rates when the assessee has opted for the new tax regime under Section 115BAC(1A) and the total income is below the threshold.

Which sections of the Income-tax Act were involved?

Section 87A,Section 111A,Section 115BAC(1A)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Rajkot Bench, Rajkot

Before: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

Hearing: 04/02/2026Pronounced: 22/04/2026

Per, Dr. Arjun Lal Saini, AM: Captioned appeal filed by the assessee, pertaining to Assessment Year 2024-25, is directed against the order passed under section 250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) by Learned Commissioner of Income Tax (Appeals), Addl/JCIT(A)-3, Bengaluru, [in short, Ld. CIT(A)], dated 07.11.2025, which in turn arises out of an assessment order passed by the Assess

The order continues below.

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